Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The CBIC clarified that late fee under section 47(2) of the CGST Act applies to delayed filing of complete annual returns under section 44, which includes both FORM GSTR-9 and GSTR-9C (where required). Late fee is calculated from the due date until the complete return is furnished. For taxpayers with aggregate turnover exceeding the threshold (5 crore post-August 2021), annual return filing is incomplete without GSTR-9C. Per Notification No. 08/2025-Central Tax, excess late fee for financial years up to FY 2022-23 is waived if GSTR-9C is filed by March 31, 2025, with no additional fee beyond what was payable up to the GSTR-9 filing date. No refunds are available for late fees already paid.
The CBIC clarified that late fee under section 47(2) of the CGST Act applies to delayed filing of complete annual returns under section 44, which includes both FORM GSTR-9 and GSTR-9C (where required). Late fee is calculated from the due date until the complete return is furnished. For taxpayers with aggregate turnover exceeding the threshold (5 crore post-August 2021), annual return filing is incomplete without GSTR-9C. Per Notification No. 08/2025-Central Tax, excess late fee for financial years up to FY 2022-23 is waived if GSTR-9C is filed by March 31, 2025, with no additional fee beyond what was payable up to the GSTR-9 filing date. No refunds are available for late fees already paid.
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