Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Adjudication cannot sustain an alleged IGST short-payment demand on input-tax-credit eligibility grounds absent from the show-cause notice, particularly where the explanation for payment under different GST heads remains unaddressed. Payment of CGST and SGST instead of IGST because of a clerical error constitutes wrong-head payment rather than non-payment or short payment. Excess CGST and SGST credit should be set off against the IGST liability through the electronic credit ledger, with only any balance remaining after set-off recoverable in cash together with applicable interest.
Adjudication cannot sustain an alleged IGST short-payment demand on input-tax-credit eligibility grounds absent from the show-cause notice, particularly where the explanation for payment under different GST heads remains unaddressed. Payment of CGST and SGST instead of IGST because of a clerical error constitutes wrong-head payment rather than non-payment or short payment. Excess CGST and SGST credit should be set off against the IGST liability through the electronic credit ledger, with only any balance remaining after set-off recoverable in cash together with applicable interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
