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 SGST Commissioner amended the delegation of functions under the Kerala State Goods and Services Tax Act, 2017, specifically concerning the waiver scheme under newly inserted Section 128A effective 01.11.2024. The proper officer for processing waiver applications relating to notices under Section 73 remains the officer authorized under that section, while applications relating to orders under Section 73 are assigned to officers delegated under Section 79. Pursuant to Instruction No. 06/2025, these functions are now assigned to Deputy State Tax Officers/Assistant State Tax Officers within the Taxpayer Services vertical to ensure timely processing within pecuniary limits. The amendment to Circular No. 5/2023 took effect from 15.03.2025, streamlining officer responsibilities for waiver applications.
The Kerala SGST Commissioner amended the delegation of functions under the Kerala State Goods and Services Tax Act, 2017, specifically concerning the waiver scheme under newly inserted Section 128A effective 01.11.2024. The proper officer for processing waiver applications relating to notices under Section 73 remains the officer authorized under that section, while applications relating to orders under Section 73 are assigned to officers delegated under Section 79. Pursuant to Instruction No. 06/2025, these functions are now assigned to Deputy State Tax Officers/Assistant State Tax Officers within the Taxpayer Services vertical to ensure timely processing within pecuniary limits. The amendment to Circular No. 5/2023 took effect from 15.03.2025, streamlining officer responsibilities for waiver applications.
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