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...
Clarifies that in cases of import of services by a registered person in India from a related person located outside India, where the recipient is eligible for full input tax credit, the value declared in the invoice by the recipient shall be deemed as open market value as per the second proviso to Rule 28(1) of KGST Rules. Further, if no invoice is issued by the recipient for services provided by the foreign affiliate, the value may be deemed as Nil and treated as open market value under the same provision. Directs trade notices to publicize the circular and address implementation difficulties.
Clarifies that in cases of import of services by a registered person in India from a related person located outside India, where the recipient is eligible for full input tax credit, the value declared in the invoice by the recipient shall be deemed as open market value as per the second proviso to Rule 28(1) of KGST Rules. Further, if no invoice is issued by the recipient for services provided by the foreign affiliate, the value may be deemed as Nil and treated as open market value under the same provision. Directs trade notices to publicize the circular and address implementation difficulties.
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