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 tax authority withdraws its prior circular dated 26 June 2024 that had prescribed a procedure for suppliers to provide evidence of compliance with Section 15(3)(b)(ii) of the CGST Act concerning reversal of input tax credit for discounts; the withdrawn procedure is no longer required. Field formations are directed to publicize the withdrawal via trade notices and to report any implementation difficulties to the authority.
The tax authority withdraws its prior circular dated 26 June 2024 that had prescribed a procedure for suppliers to provide evidence of compliance with Section 15(3)(b)(ii) of the CGST Act concerning reversal of input tax credit for discounts; the withdrawn procedure is no longer required. Field formations are directed to publicize the withdrawal via trade notices and to report any implementation difficulties to the authority.
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