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 Kerala State GST Department issued Circular No. 14/2025 implementing procedural changes for adjudication under Section 74A of the KSGST Act, 2017. Section 74A, inserted through the Kerala Taxation Laws (Amendment) Act, 2024, standardizes timeframes for tax determination and penalty relief regardless of fraud or suppression circumstances, superseding Sections 73 and 74. All show cause notices under Section 74A must be adjudicated by jurisdictional authorities within the Taxpayer Services Vertical, shifting responsibility from Intelligence, Enforcement, and Audit verticals. The circular mandates uniform numbering formats for notices and orders consistent with existing Section 73/74 procedures, utilizing the same registers and documentation systems. These administrative restructuring instructions became effective November 1, 2024, streamlining GST adjudication processes across departmental verticals.
The Kerala State GST Department issued Circular No. 14/2025 implementing procedural changes for adjudication under Section 74A of the KSGST Act, 2017. Section 74A, inserted through the Kerala Taxation Laws (Amendment) Act, 2024, standardizes timeframes for tax determination and penalty relief regardless of fraud or suppression circumstances, superseding Sections 73 and 74. All show cause notices under Section 74A must be adjudicated by jurisdictional authorities within the Taxpayer Services Vertical, shifting responsibility from Intelligence, Enforcement, and Audit verticals. The circular mandates uniform numbering formats for notices and orders consistent with existing Section 73/74 procedures, utilizing the same registers and documentation systems. These administrative restructuring instructions became effective November 1, 2024, streamlining GST adjudication processes across departmental verticals.
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