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 Delhi State Tax Commissioner issued Circular No. 22/2024 adopting CBIC Circular No. 228/22/2024 regarding GST applicability clarifications. The circular addresses eight key areas: exempting specific Railway services to general public and inter-zone transactions with retrospective regularization from October 2023; exempting SPV-Railway infrastructure transactions with regularization from July 2017; clarifying RERA statutory collections are exempt under existing notifications; confirming digital payment incentives shared per NPCI guidelines remain non-taxable subsidies; regularizing reinsurance GST liability for exempt insurance schemes from July 2017 to January 2018; regularizing government-premium insurance reinsurance from July 2017 to July 2018; clarifying reinsurance includes retrocession services; and exempting accommodation services under 20,000 monthly for minimum 90-day periods with retrospective regularization from July 2017. All regularizations apply on "as is where is" basis.
The Delhi State Tax Commissioner issued Circular No. 22/2024 adopting CBIC Circular No. 228/22/2024 regarding GST applicability clarifications. The circular addresses eight key areas: exempting specific Railway services to general public and inter-zone transactions with retrospective regularization from October 2023; exempting SPV-Railway infrastructure transactions with regularization from July 2017; clarifying RERA statutory collections are exempt under existing notifications; confirming digital payment incentives shared per NPCI guidelines remain non-taxable subsidies; regularizing reinsurance GST liability for exempt insurance schemes from July 2017 to January 2018; regularizing government-premium insurance reinsurance from July 2017 to July 2018; clarifying reinsurance includes retrocession services; and exempting accommodation services under 20,000 monthly for minimum 90-day periods with retrospective regularization from July 2017. All regularizations apply on "as is where is" basis.
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