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 treatment of tax on credit notes for returned goods requires distinguishing a GSTR-3B/GSTR-2A mismatch from wrongful input tax credit. Credit-note tax relating to the supplier's own outward supply is not input tax and should reduce output tax liability; where credit notes are timely declared, original output tax was paid, and no duplicate reduction or revenue loss arises, incorrect return-table reporting is procedural. A demand must remain within the grounds stated in the show cause notice. For 2017-18, recipient reversal of credit was not a condition for the supplier's output-tax reduction; recipient non-reversal is separately assessable. Interest and penalty depend on tax being due.
GST treatment of tax on credit notes for returned goods requires distinguishing a GSTR-3B/GSTR-2A mismatch from wrongful input tax credit. Credit-note tax relating to the supplier's own outward supply is not input tax and should reduce output tax liability; where credit notes are timely declared, original output tax was paid, and no duplicate reduction or revenue loss arises, incorrect return-table reporting is procedural. A demand must remain within the grounds stated in the show cause notice. For 2017-18, recipient reversal of credit was not a condition for the supplier's output-tax reduction; recipient non-reversal is separately assessable. Interest and penalty depend on tax being due.
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