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 amended the CGST Rules, 2017 through Notification No. 11/2025-Central Tax dated March 27, 2025. The amendments modify Rule 164 regarding tax payments and refunds. Key changes include: (1) clarification that no refund shall be available for tax, interest, and penalties already discharged prior to these amendments where notices include demands partially within and partially outside specified periods; (2) introduction of a procedure allowing appellants to partially pursue appeals by intimating appellate authorities they do not wish to pursue appeals for specific periods (July 1, 2017 to March 31, 2020). Such intimations will be deemed as partial withdrawal of appeals. The amendments took effect upon official publication.
The Central Government amended the CGST Rules, 2017 through Notification No. 11/2025-Central Tax dated March 27, 2025. The amendments modify Rule 164 regarding tax payments and refunds. Key changes include: (1) clarification that no refund shall be available for tax, interest, and penalties already discharged prior to these amendments where notices include demands partially within and partially outside specified periods; (2) introduction of a procedure allowing appellants to partially pursue appeals by intimating appellate authorities they do not wish to pursue appeals for specific periods (July 1, 2017 to March 31, 2020). Such intimations will be deemed as partial withdrawal of appeals. The amendments took effect upon official publication.
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