SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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 
