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...
Entry 27 exempts services of extending deposits, loans or advances where consideration is represented by interest or discount, except interest in credit-card services; qualifying interest recovery is therefore exempt from GST. A taxpayer claiming that turnover reported in one State actually comprised exempt interest attributable to another State must prove that assertion through cogent documentary evidence. Form GSTR-09C and a Chartered Accountant's certificate without disclosed findings or identifiable documentary support do not discharge that burden. Failure to provide supporting evidence permits an adverse inference, leaving the disputed turnover unestablished as exempt interest and resulting in rejection of the claim.
Entry 27 exempts services of extending deposits, loans or advances where consideration is represented by interest or discount, except interest in credit-card services; qualifying interest recovery is therefore exempt from GST. A taxpayer claiming that turnover reported in one State actually comprised exempt interest attributable to another State must prove that assertion through cogent documentary evidence. Form GSTR-09C and a Chartered Accountant's certificate without disclosed findings or identifiable documentary support do not discharge that burden. Failure to provide supporting evidence permits an adverse inference, leaving the disputed turnover unestablished as exempt interest and resulting in rejection of the claim.
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