Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
Note: It is a system-generated summary and is for quick reference only.