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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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