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 CBIC issued guidelines regarding recovery of outstanding dues in cases where the first appellate authority has confirmed the demand, partially or fully, but appeals against such orders could not be filed due to non-constitution of the Appellate Tribunal. Taxpayers can pay the pre-deposit amount through the Electronic Liability Register and file an undertaking to appeal before the Tribunal when constituted. This will stay recovery of the remaining demand as per Section 112(9) of the CGST Act. Amounts inadvertently paid through FORM GST DRC-03, intended towards demand, can be adjusted against the pre-deposit through FORM GST DRC-03A once functionality is available on the common portal.
The CBIC issued guidelines regarding recovery of outstanding dues in cases where the first appellate authority has confirmed the demand, partially or fully, but appeals against such orders could not be filed due to non-constitution of the Appellate Tribunal. Taxpayers can pay the pre-deposit amount through the Electronic Liability Register and file an undertaking to appeal before the Tribunal when constituted. This will stay recovery of the remaining demand as per Section 112(9) of the CGST Act. Amounts inadvertently paid through FORM GST DRC-03, intended towards demand, can be adjusted against the pre-deposit through FORM GST DRC-03A once functionality is available on the common portal.
Note: It is a system-generated summary and is for quick reference only.
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