Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Legal Circular Analysis: The circular addresses key interpretative issues regarding Section 128A of the Assam GST Act, 2017, specifically clarifying two critical points. First, taxpayers who paid taxes through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification. Second, for notices/orders spanning periods partially covered and outside Section 128A, taxpayers can file specific forms (SPL-01/SPL-02) after paying tax liabilities for covered periods, with appellate authorities empowered to adjudicate remaining periods independently. The guidance aims to provide procedural clarity and administrative flexibility in tax dispute resolution, ensuring uniform implementation across tax jurisdictions.
Legal Circular Analysis: The circular addresses key interpretative issues regarding Section 128A of the Assam GST Act, 2017, specifically clarifying two critical points. First, taxpayers who paid taxes through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification. Second, for notices/orders spanning periods partially covered and outside Section 128A, taxpayers can file specific forms (SPL-01/SPL-02) after paying tax liabilities for covered periods, with appellate authorities empowered to adjudicate remaining periods independently. The guidance aims to provide procedural clarity and administrative flexibility in tax dispute resolution, ensuring uniform implementation across tax jurisdictions.
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