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...
Circular clarifies GST treatment of secondary/post-sale discounts: when suppliers issue financial/commercial credit notes that do not reduce the original transaction value, recipients need not reverse input tax credit as the supplier's tax liability remains unchanged. Post-sale discounts from a manufacturer to a dealer are generally viewed as price reductions between independent sales (manufacturer→dealer; dealer→customer) and are not treated as consideration for inducement of the dealer's supply, unless the manufacturer has a direct agreement with the end customer-then such discounts should be included in overall consideration. Discounts are not consideration for promotional services unless a separate agreement specifies distinct services and consideration.
Circular clarifies GST treatment of secondary/post-sale discounts: when suppliers issue financial/commercial credit notes that do not reduce the original transaction value, recipients need not reverse input tax credit as the supplier's tax liability remains unchanged. Post-sale discounts from a manufacturer to a dealer are generally viewed as price reductions between independent sales (manufacturer→dealer; dealer→customer) and are not treated as consideration for inducement of the dealer's supply, unless the manufacturer has a direct agreement with the end customer-then such discounts should be included in overall consideration. Discounts are not consideration for promotional services unless a separate agreement specifies distinct services and consideration.
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