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...
Tax paid under the CGST and SGST heads through a clerical error may be appropriated towards the corresponding IGST liability where the entire liability was discharged within the prescribed period. Although Section 77 does not expressly address this payment error, its underlying principle avoids requiring the taxable person to make a duplicate payment and then pursue a refund. Interest should not apply where the required tax has already been remitted, albeit under incorrect GST heads. Appropriation may be made on application, with a refund application filed if required procedurally.
Tax paid under the CGST and SGST heads through a clerical error may be appropriated towards the corresponding IGST liability where the entire liability was discharged within the prescribed period. Although Section 77 does not expressly address this payment error, its underlying principle avoids requiring the taxable person to make a duplicate payment and then pursue a refund. Interest should not apply where the required tax has already been remitted, albeit under incorrect GST heads. Appropriation may be made on application, with a refund application filed if required procedurally.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
