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...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Wrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect tax head, are distinct from a later correction of a supply's inter-State or intra-State character. Sections 19 of the IGST Act and 77 of the CGST Act, with Rule 89(1A), address classification errors and the related refund framework, not a pure allocation error. An identifiable wrong-head payment may be appropriated against the correct CGST and SGST liabilities rather than requiring duplicate payment followed by refund. Where funds remain in the electronic cash ledger, Section 49(10) and Rule 87(13) permit inter-head transfer through FORM GST PMT-09; refund may be procedurally necessary if transfer is unavailable.
Wrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect tax head, are distinct from a later correction of a supply's inter-State or intra-State character. Sections 19 of the IGST Act and 77 of the CGST Act, with Rule 89(1A), address classification errors and the related refund framework, not a pure allocation error. An identifiable wrong-head payment may be appropriated against the correct CGST and SGST liabilities rather than requiring duplicate payment followed by refund. Where funds remain in the electronic cash ledger, Section 49(10) and Rule 87(13) permit inter-head transfer through FORM GST PMT-09; refund may be procedurally necessary if transfer is unavailable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
