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 provided on time of supply of services for spectrum usage and other similar services under GST. For spectrum allocation, where telecom operator opts for deferred payment, it constitutes continuous supply of services as defined u/s 2(33) of WBGST Act. Time of supply governed by section 13(3) of WBGST Act, being earlier of payment date or 60 days from document issue date. Frequency Assignment Letter not considered invoice for 60-day period calculation. Invoice required on or before due date per section 31(5)(a). For upfront payment, GST payable when payment made or due, whichever earlier. For deferred instalments, GST payable as instalments due or paid, whichever earlier. Similar treatment for other natural resource allocations constituting continuous supply.
Clarification provided on time of supply of services for spectrum usage and other similar services under GST. For spectrum allocation, where telecom operator opts for deferred payment, it constitutes continuous supply of services as defined u/s 2(33) of WBGST Act. Time of supply governed by section 13(3) of WBGST Act, being earlier of payment date or 60 days from document issue date. Frequency Assignment Letter not considered invoice for 60-day period calculation. Invoice required on or before due date per section 31(5)(a). For upfront payment, GST payable when payment made or due, whichever earlier. For deferred instalments, GST payable as instalments due or paid, whichever earlier. Similar treatment for other natural resource allocations constituting continuous supply.
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