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 CBIC clarified through Circular No. 240/34/2024-GST that electronic commerce operators liable to pay tax under Section 9(5) of CGST Act are not required to reverse input tax credit proportionately on inputs and input services for supplies made under Section 9(5). This extends the principle established in Circular No. 167/23/2021-GST for restaurant services to all services specified under Section 9(5). ECOs must pay the entire tax liability under Section 9(5) through electronic cash ledger only, without utilizing available ITC for such payments. However, ECOs may utilize ITC for discharging tax liability on their own service supplies. The Delhi State Tax Department adopted this clarification mutatis mutandis for uniform implementation under DGST Act, 2017.
The CBIC clarified through Circular No. 240/34/2024-GST that electronic commerce operators liable to pay tax under Section 9(5) of CGST Act are not required to reverse input tax credit proportionately on inputs and input services for supplies made under Section 9(5). This extends the principle established in Circular No. 167/23/2021-GST for restaurant services to all services specified under Section 9(5). ECOs must pay the entire tax liability under Section 9(5) through electronic cash ledger only, without utilizing available ITC for such payments. However, ECOs may utilize ITC for discharging tax liability on their own service supplies. The Delhi State Tax Department adopted this clarification mutatis mutandis for uniform implementation under DGST Act, 2017.
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