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...
ECOs liable for tax under Sec 9(5) of WBGST Act are not required to reverse input tax credit on inputs and input services proportionately for specified services supplied through their platforms. While ECOs must pay full tax liability for Sec 9(5) supplies through electronic cash ledger only, they can utilize their ITC for tax obligations on their own account services like platform fees. The clarification extends the principle previously established for restaurant services to all specified services under Sec 9(5). ECOs operate in dual capacity - as deemed suppliers for notified services and as platform service providers charging commission. Their ITC remains valid for platform operations but cannot offset Sec 9(5) tax liabilities.
ECOs liable for tax under Sec 9(5) of WBGST Act are not required to reverse input tax credit on inputs and input services proportionately for specified services supplied through their platforms. While ECOs must pay full tax liability for Sec 9(5) supplies through electronic cash ledger only, they can utilize their ITC for tax obligations on their own account services like platform fees. The clarification extends the principle previously established for restaurant services to all specified services under Sec 9(5). ECOs operate in dual capacity - as deemed suppliers for notified services and as platform service providers charging commission. Their ITC remains valid for platform operations but cannot offset Sec 9(5) tax liabilities.
Note: It is a system-generated summary and is for quick reference only.