Agent classification determines whether interest charged by a del credere agent is included in the taxable value of goods. Classification of a del credere agent under Para 3 of Schedule I depends on invoicing: supplier issued invoices (even via DCA) mean the DCA is not an agent; DCA issued invoices mean the DCA is an agent. If the DCA is not an agent, loans/interest by DCA are independent supplies by the DCA and interest is not includible in the supplier's goods value. If the DCA is an agent, credit extended is subsumed into the goods supply and interest must be included in taxable value under section 15(2)(d).
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Provisions expressly mentioned in the judgment/order text.
Agent classification determines whether interest charged by a del credere agent is included in the taxable value of goods.
Classification of a del credere agent under Para 3 of Schedule I depends on invoicing: supplier issued invoices (even via DCA) mean the DCA is not an agent; DCA issued invoices mean the DCA is an agent. If the DCA is not an agent, loans/interest by DCA are independent supplies by the DCA and interest is not includible in the supplier's goods value. If the DCA is an agent, credit extended is subsumed into the goods supply and interest must be included in taxable value under section 15(2)(d).
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