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 provides instructions for adjudication of show cause notices (SCNs) issued by various verticals under the Kerala State Goods and Services Tax Act, 2017. To ensure uniformity and consistency, a common adjudicating authority is designated for cases involving multiple taxpayers across the state interconnected in a single issue. Joint Commissioners of Taxpayer Services are empowered with state-wide jurisdiction for this purpose. The SCNs will be adjudicated by the Joint Commissioner of the district where the noticee with the highest tax/penalty demand is located. If multiple noticees are in the same district, the Joint Commissioner of that district will adjudicate all SCNs, irrespective of the amount involved. Connected penalty notices will also be adjudicated by the common authority. Previous circulars on the matter stand withdrawn, with actions already initiated remaining valid.
The circular provides instructions for adjudication of show cause notices (SCNs) issued by various verticals under the Kerala State Goods and Services Tax Act, 2017. To ensure uniformity and consistency, a common adjudicating authority is designated for cases involving multiple taxpayers across the state interconnected in a single issue. Joint Commissioners of Taxpayer Services are empowered with state-wide jurisdiction for this purpose. The SCNs will be adjudicated by the Joint Commissioner of the district where the noticee with the highest tax/penalty demand is located. If multiple noticees are in the same district, the Joint Commissioner of that district will adjudicate all SCNs, irrespective of the amount involved. Connected penalty notices will also be adjudicated by the common authority. Previous circulars on the matter stand withdrawn, with actions already initiated remaining valid.
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