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 Central Government has waived excess late fees u/s 47 of CGST Act for registered persons who failed to file GSTR-9C reconciliation statements alongside GSTR-9 annual returns for FY 2017-18 through 2022-23. This waiver applies to late fees exceeding the prescribed amount u/s 47, provided the pending GSTR-9C is filed by March 31, 2025. The notification, issued u/s 128 of CGST Act upon GST Council's recommendation, specifically excludes refunds of any late fees already paid for delayed GSTR-9C submissions during these financial years. The waiver aims to facilitate compliance for taxpayers who have outstanding reconciliation statement obligations.
The Central Government has waived excess late fees u/s 47 of CGST Act for registered persons who failed to file GSTR-9C reconciliation statements alongside GSTR-9 annual returns for FY 2017-18 through 2022-23. This waiver applies to late fees exceeding the prescribed amount u/s 47, provided the pending GSTR-9C is filed by March 31, 2025. The notification, issued u/s 128 of CGST Act upon GST Council's recommendation, specifically excludes refunds of any late fees already paid for delayed GSTR-9C submissions during these financial years. The waiver aims to facilitate compliance for taxpayers who have outstanding reconciliation statement obligations.
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