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 APGST circular addresses multiple GST-related clarifications following the 55th GST Council meeting. Key outcomes include: (1) No GST on penal charges levied by Regulated Entities per RBI instructions, (2) GST exemption confirmed for Payment Aggregators settling transactions up to 2,000, (3) Regularization of GST payment for research and development services from 2017-2024, (4) Restoration of GST exemption for NSDC-approved Training Partners, (5) Regularization of GST on commercial property rental under Reverse Charge Mechanism for composition levy taxpayers, and (6) Regularization of GST on incidental electricity transmission and distribution utility services from October 2024 to January 2025, all implemented on an 'as is where is' basis.
The APGST circular addresses multiple GST-related clarifications following the 55th GST Council meeting. Key outcomes include: (1) No GST on penal charges levied by Regulated Entities per RBI instructions, (2) GST exemption confirmed for Payment Aggregators settling transactions up to 2,000, (3) Regularization of GST payment for research and development services from 2017-2024, (4) Restoration of GST exemption for NSDC-approved Training Partners, (5) Regularization of GST on commercial property rental under Reverse Charge Mechanism for composition levy taxpayers, and (6) Regularization of GST on incidental electricity transmission and distribution utility services from October 2024 to January 2025, all implemented on an 'as is where is' basis.
Note: It is a system-generated summary and is for quick reference only.