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 clarifies two key issues regarding Section 128A of CGST Act, which provides waiver of interest/penalty for demands under Section 73 for July 2017-March 2020 period. First, taxpayers who made payments through GSTR-3B before November 1, 2024 (when Section 128A came into force) are eligible for the benefit, though payments after this date must follow prescribed modes under Rule 164. Second, for notices/orders covering periods partially within and partially outside Section 128A's scope, taxpayers can file Form SPL-01 or SPL-02 after paying tax liability for the covered period only, and may inform the appellate authority of their intent not to pursue appeals for the 2017-20 period while continuing litigation for other periods.
The CBIC clarifies two key issues regarding Section 128A of CGST Act, which provides waiver of interest/penalty for demands under Section 73 for July 2017-March 2020 period. First, taxpayers who made payments through GSTR-3B before November 1, 2024 (when Section 128A came into force) are eligible for the benefit, though payments after this date must follow prescribed modes under Rule 164. Second, for notices/orders covering periods partially within and partially outside Section 128A's scope, taxpayers can file Form SPL-01 or SPL-02 after paying tax liability for the covered period only, and may inform the appellate authority of their intent not to pursue appeals for the 2017-20 period while continuing litigation for other periods.
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