Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Royalty payable for a State Government grant of mineral extraction rights under a Short-Term Permit is contractual consideration for licensing services involving the right to use minerals, rather than a tax. The permit holder, as recipient of a Government-to-business supply, must discharge GST under reverse charge at 18%. The shorter duration and restricted area of a Short-Term Permit do not change the nature of the supply where the grantor, extraction rights and royalty basis correspond to those for quarry and mining leases. Short-Term Permit holders therefore receive the same reverse-charge GST treatment as quarry and mining lease holders.
Royalty payable for a State Government grant of mineral extraction rights under a Short-Term Permit is contractual consideration for licensing services involving the right to use minerals, rather than a tax. The permit holder, as recipient of a Government-to-business supply, must discharge GST under reverse charge at 18%. The shorter duration and restricted area of a Short-Term Permit do not change the nature of the supply where the grantor, extraction rights and royalty basis correspond to those for quarry and mining leases. Short-Term Permit holders therefore receive the same reverse-charge GST treatment as quarry and mining lease holders.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
