Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
GST registration may be cancelled for continuous non-filing of returns under Section 29, but cancellation does not extinguish pre-cancellation tax liabilities. Rule 22 requires notice and an opportunity to respond; where pending returns are filed and tax, interest and late fee are fully paid before cancellation, the officer must drop proceedings. Post-cancellation revocation under Rule 23 requires compliance with prescribed filing, payment and limitation conditions, while appellate authorities cannot exceed statutory condonation limits. Defective notices, absence of reasons, denial of meaningful hearing, or unexplained retrospective cancellation may invalidate the process. Conditional restoration may be available in appropriate non-fraud cases upon full regularisation of returns, tax, interest, late fee and penalty.
GST registration may be cancelled for continuous non-filing of returns under Section 29, but cancellation does not extinguish pre-cancellation tax liabilities. Rule 22 requires notice and an opportunity to respond; where pending returns are filed and tax, interest and late fee are fully paid before cancellation, the officer must drop proceedings. Post-cancellation revocation under Rule 23 requires compliance with prescribed filing, payment and limitation conditions, while appellate authorities cannot exceed statutory condonation limits. Defective notices, absence of reasons, denial of meaningful hearing, or unexplained retrospective cancellation may invalidate the process. Conditional restoration may be available in appropriate non-fraud cases upon full regularisation of returns, tax, interest, late fee and penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
