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...
CBIC issued Circular No. 250/07/2025-GST clarifying jurisdictional authorities for review, revision, and appeals regarding orders passed by Common Adjudicating Authority (CAA) on DGGI show cause notices. Under CGST Act Sections 107-108, the Principal Commissioner or Commissioner under whom CAA is posted serves as reviewing and revisional authority. Appeals lie before Commissioner (Appeals) within corresponding territorial jurisdiction per notification 02/2017. The same Principal Commissioner/Commissioner represents department in appeal proceedings and may appoint subordinate officers for filing departmental appeals. Reviewing/revisional authorities may seek DGGI comments before deciding on CAA orders, ensuring uniform procedural compliance across all adjudication matters.
CBIC issued Circular No. 250/07/2025-GST clarifying jurisdictional authorities for review, revision, and appeals regarding orders passed by Common Adjudicating Authority (CAA) on DGGI show cause notices. Under CGST Act Sections 107-108, the Principal Commissioner or Commissioner under whom CAA is posted serves as reviewing and revisional authority. Appeals lie before Commissioner (Appeals) within corresponding territorial jurisdiction per notification 02/2017. The same Principal Commissioner/Commissioner represents department in appeal proceedings and may appoint subordinate officers for filing departmental appeals. Reviewing/revisional authorities may seek DGGI comments before deciding on CAA orders, ensuring uniform procedural compliance across all adjudication matters.
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