Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Input tax credit mismatches between Forms GSTR-3B and GSTR-2A may support tax determination under section 73, but do not by themselves justify section 74 proceedings or penalties. Section 74 requires clear evidence connecting wrongful credit availment with fraud, wilful misstatement, or suppression of facts intended to evade tax; merely reciting those terms is insufficient. Payment of tax and interest before notice, including after verification, falls within section 73(5) where no intent to evade is established. A supplier's default cannot automatically be attributed to the recipient as suppression.
Input tax credit mismatches between Forms GSTR-3B and GSTR-2A may support tax determination under section 73, but do not by themselves justify section 74 proceedings or penalties. Section 74 requires clear evidence connecting wrongful credit availment with fraud, wilful misstatement, or suppression of facts intended to evade tax; merely reciting those terms is insufficient. Payment of tax and interest before notice, including after verification, falls within section 73(5) where no intent to evade is established. A supplier's default cannot automatically be attributed to the recipient as suppression.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
