Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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