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...
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GST interest on delayed GSTR-3B liabilities remains payable on the cash component until the Electronic Cash Ledger is debited, even where sufficient funds were deposited and continuously available earlier. A ledger credit evidences deposit with the Government but does not discharge an identified tax liability; debit is required for payment. The proviso excluding continuously available cash-ledger balances from interest computation operates prospectively and does not apply to earlier periods. A show-cause notice causes no defect where the taxpayer received the demand computation, responded fully, and suffered no prejudice. Failure to provide a requested personal hearing breached statutory requirements, but remand was unnecessary absent surviving substantive prejudice. Interest demands remain subject to reconciliation and credit without double recovery.
GST interest on delayed GSTR-3B liabilities remains payable on the cash component until the Electronic Cash Ledger is debited, even where sufficient funds were deposited and continuously available earlier. A ledger credit evidences deposit with the Government but does not discharge an identified tax liability; debit is required for payment. The proviso excluding continuously available cash-ledger balances from interest computation operates prospectively and does not apply to earlier periods. A show-cause notice causes no defect where the taxpayer received the demand computation, responded fully, and suffered no prejudice. Failure to provide a requested personal hearing breached statutory requirements, but remand was unnecessary absent surviving substantive prejudice. Interest demands remain subject to reconciliation and credit without double recovery.
Note: It is a system-generated summary and is for quick reference only.
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