Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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