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 Karnataka Commercial Taxes Dept issued a circular clarifying the implementation of Section 128A of the KGST Act, 2017. The circular addresses two key issues: (1) taxpayers who paid tax through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification; and (2) for notices/orders spanning periods partially within and outside Section 128A's scope, taxpayers can file specific forms (SPL-01/SPL-02) after paying tax liability for covered periods, with appellate authorities empowered to adjudicate remaining periods appropriately. The circular aims to provide clarity and uniformity in implementing the statutory provisions.
The Karnataka Commercial Taxes Dept issued a circular clarifying the implementation of Section 128A of the KGST Act, 2017. The circular addresses two key issues: (1) taxpayers who paid tax through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification; and (2) for notices/orders spanning periods partially within and outside Section 128A's scope, taxpayers can file specific forms (SPL-01/SPL-02) after paying tax liability for covered periods, with appellate authorities empowered to adjudicate remaining periods appropriately. The circular aims to provide clarity and uniformity in implementing the statutory provisions.
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