Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Challenge to invocation of the extended period under s.74 of the TNGST Act was considered in light of an unclear show-cause notice and the alleged mismatch between GSTR-2A and GSTR-3B. The court held that proper adjudication on limitation and tax liability required the taxpayer to furnish a comprehensive reply on merits along with legal submissions, which had not been effectively done, warranting a fresh determination. Accordingly, the impugned order was quashed and the matter remitted to the proper officer for reconsideration, subject to deposit of 10% of the disputed tax from the taxpayer's electronic cash ledger within 30 days. - HC
Challenge to invocation of the extended period under s.74 of the TNGST Act was considered in light of an unclear show-cause notice and the alleged mismatch between GSTR-2A and GSTR-3B. The court held that proper adjudication on limitation and tax liability required the taxpayer to furnish a comprehensive reply on merits along with legal submissions, which had not been effectively done, warranting a fresh determination. Accordingly, the impugned order was quashed and the matter remitted to the proper officer for reconsideration, subject to deposit of 10% of the disputed tax from the taxpayer's electronic cash ledger within 30 days. - HC
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