Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Taxability issues surrounding personal and corporate guarantees in the realm of Goods and Services Tax (GST). - The circular extends its clarification to corporate guarantees provided by one company for another related company or by a holding company for its subsidiary. These guarantees, too, are considered supplies of service between related persons under the HGST / GST Act, thereby attracting GST. It further specifies that the valuation of such supplies will follow Rule 28 of the HGST Rules, with a recent amendment introduced through Notification, to ensure uniformity in valuation practices.
Taxability issues surrounding personal and corporate guarantees in the realm of Goods and Services Tax (GST). - The circular extends its clarification to corporate guarantees provided by one company for another related company or by a holding company for its subsidiary. These guarantees, too, are considered supplies of service between related persons under the HGST / GST Act, thereby attracting GST. It further specifies that the valuation of such supplies will follow Rule 28 of the HGST Rules, with a recent amendment introduced through Notification, to ensure uniformity in valuation practices.
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