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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
GST liability, including interest on delayed payment, must be determined strictly under the statute, and interest arises by operation of law where the fiscal enactment so provides. In the absence of statutory power, authorities cannot waive or reduce interest, or permit filing or amendment of returns in a manner not contemplated by the GST scheme; blanket directions on penalty and limitation are likewise unsustainable. The note also distinguishes contractual reimbursement of incremental GST from statutory tax liability: any claim for reimbursement is an inter se matter between contracting parties and cannot alter the GST regime or bind tax authorities.
GST liability, including interest on delayed payment, must be determined strictly under the statute, and interest arises by operation of law where the fiscal enactment so provides. In the absence of statutory power, authorities cannot waive or reduce interest, or permit filing or amendment of returns in a manner not contemplated by the GST scheme; blanket directions on penalty and limitation are likewise unsustainable. The note also distinguishes contractual reimbursement of incremental GST from statutory tax liability: any claim for reimbursement is an inter se matter between contracting parties and cannot alter the GST regime or bind tax authorities.
Note: It is a system-generated summary and is for quick reference only.