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...
The circular clarifies the time limit u/s 16(4) of the KGST Act, 2017, for availing input tax credit (ITC) by the recipient on tax paid under reverse charge mechanism (RCM) for supplies received from unregistered persons. It states that where the recipient is liable to pay tax on RCM supplies from unregistered suppliers and issue an invoice u/s 31(3)(f), the relevant financial year for calculating the time limit u/s 16(4) for ITC availment will be the financial year in which the invoice is issued by the recipient. The recipient must pay tax on such supplies, along with interest for delayed payment, and comply with other conditions u/ss 16 and 17 to avail ITC. Delayed issuance of invoices may also attract penal action u/s 122.
The circular clarifies the time limit u/s 16(4) of the KGST Act, 2017, for availing input tax credit (ITC) by the recipient on tax paid under reverse charge mechanism (RCM) for supplies received from unregistered persons. It states that where the recipient is liable to pay tax on RCM supplies from unregistered suppliers and issue an invoice u/s 31(3)(f), the relevant financial year for calculating the time limit u/s 16(4) for ITC availment will be the financial year in which the invoice is issued by the recipient. The recipient must pay tax on such supplies, along with interest for delayed payment, and comply with other conditions u/ss 16 and 17 to avail ITC. Delayed issuance of invoices may also attract penal action u/s 122.
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