Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Inadvertent payment of GST under the IGST head, where CGST and SGST were actually payable and no IGST liability existed, is treated as a clerical error rather than a payment made under a misconception that the supply was inter-State. Section 77(2) therefore does not apply. Where the full GST liability has effectively been discharged, interest and penalty are not payable. The amount remitted as IGST may be appropriated against the CGST and SGST liability; where procedurally required, refund and transfer of the amount may be sought.
Inadvertent payment of GST under the IGST head, where CGST and SGST were actually payable and no IGST liability existed, is treated as a clerical error rather than a payment made under a misconception that the supply was inter-State. Section 77(2) therefore does not apply. Where the full GST liability has effectively been discharged, interest and penalty are not payable. The amount remitted as IGST may be appropriated against the CGST and SGST liability; where procedurally required, refund and transfer of the amount may be sought.
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