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...
A government GST circular clarified that financial/commercial credit notes issued without GST do not require recipients to reverse input tax credit (ITC), but distributors face blocked ITC and cash-flow stress with no current refund mechanism. Experts say a proposed amendment to the CGST Act (Section 15) would allow suppliers to issue GST credit adjustments without invoice linkage, reducing recipient ITC accumulation once notified, though relief may take about a year. The circular also treats trade discounts as non-taxable when manufacturers support dealer pricing but taxable if prices are directly promised to consumers. An industry association has sought urgent guidance on ITC treatment after recent rate cuts and flagged product-specific anomalies.
A government GST circular clarified that financial/commercial credit notes issued without GST do not require recipients to reverse input tax credit (ITC), but distributors face blocked ITC and cash-flow stress with no current refund mechanism. Experts say a proposed amendment to the CGST Act (Section 15) would allow suppliers to issue GST credit adjustments without invoice linkage, reducing recipient ITC accumulation once notified, though relief may take about a year. The circular also treats trade discounts as non-taxable when manufacturers support dealer pricing but taxable if prices are directly promised to consumers. An industry association has sought urgent guidance on ITC treatment after recent rate cuts and flagged product-specific anomalies.
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