Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
CBIC monetary-limit instructions bind central tax officers, not the Tribunal. Where a composite order covers multiple demands, the total amount involved must be considered; appeals concerning recurring issues or statutory interpretation fall outside the monetary-limit bar. Duty credit scrips became exempt supplies in 2017, but their exclusion from aggregate exempt supplies for proportionate input tax credit reversal applies prospectively from 5 July 2022. The later amendment conferred a prospective benefit and did not retrospectively alter earlier reversal obligations. Extended demand proceedings require material showing fraud, wilful misstatement or deliberate suppression intended to evade tax; mere non-declaration is insufficient. Absent such material, tax liability must be determined under the ordinary demand procedure after hearing the taxpayer.
CBIC monetary-limit instructions bind central tax officers, not the Tribunal. Where a composite order covers multiple demands, the total amount involved must be considered; appeals concerning recurring issues or statutory interpretation fall outside the monetary-limit bar. Duty credit scrips became exempt supplies in 2017, but their exclusion from aggregate exempt supplies for proportionate input tax credit reversal applies prospectively from 5 July 2022. The later amendment conferred a prospective benefit and did not retrospectively alter earlier reversal obligations. Extended demand proceedings require material showing fraud, wilful misstatement or deliberate suppression intended to evade tax; mere non-declaration is insufficient. Absent such material, tax liability must be determined under the ordinary demand procedure after hearing the taxpayer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
