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...
Clarification on TCS liability under section 52 of the DGST Act, 2017 in case of multiple E-commerce Operators in one transaction - The circular clarifies the TCS liability under section 52 of the DGST Act concerning transactions involving multiple ECOs. It distinguishes between scenarios where the supplier-side ECO is and isn't the direct supplier, attributing TCS compliance to the entity responsible for remitting payment to the supplier. In cases where the supplier-side ECO acts solely as a facilitator, it bears the TCS burden, whereas, when the supplier-side ECO is also the supplier, the buyer-side ECO assumes TCS collection responsibilities.
Clarification on TCS liability under section 52 of the DGST Act, 2017 in case of multiple E-commerce Operators in one transaction - The circular clarifies the TCS liability under section 52 of the DGST Act concerning transactions involving multiple ECOs. It distinguishes between scenarios where the supplier-side ECO is and isn't the direct supplier, attributing TCS compliance to the entity responsible for remitting payment to the supplier. In cases where the supplier-side ECO acts solely as a facilitator, it bears the TCS burden, whereas, when the supplier-side ECO is also the supplier, the buyer-side ECO assumes TCS collection responsibilities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
