Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
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