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 clarified that for online services supplied by suppliers or through e-commerce operators to unregistered recipients, irrespective of the supply value, the tax invoice must mandatorily mention the recipient's state name. This state name shall be deemed the recipient's address on record for determining the place of supply u/s 12(2)(b)(i) of IGST Act as the recipient's location. Suppliers must devise mechanisms to collect state details from unregistered recipients before supply. Non-compliance may attract penal action u/s 122(3)(e) of CGST Act.
The CBIC clarified that for online services supplied by suppliers or through e-commerce operators to unregistered recipients, irrespective of the supply value, the tax invoice must mandatorily mention the recipient's state name. This state name shall be deemed the recipient's address on record for determining the place of supply u/s 12(2)(b)(i) of IGST Act as the recipient's location. Suppliers must devise mechanisms to collect state details from unregistered recipients before supply. Non-compliance may attract penal action u/s 122(3)(e) of CGST Act.
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