Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Exemption from GST - Collection of tax at source u/s 52 - Electronic commerce operator - Exclusion of "Agent" - Exemption under Notification No. 52/2018 - The AAR determined that the applicant operates as an electronic commerce operator, not as an agent of DGIPL. Despite the applicant's contention of acting merely as a platform for transactions between DGIPL and customers, the agreement terms and the handling of transactions classify the applicant as an E-commerce operator responsible for tax collection at source under Section 52 of the CGST Act.
Exemption from GST - Collection of tax at source u/s 52 - Electronic commerce operator - Exclusion of "Agent" - Exemption under Notification No. 52/2018 - The AAR determined that the applicant operates as an electronic commerce operator, not as an agent of DGIPL. Despite the applicant's contention of acting merely as a platform for transactions between DGIPL and customers, the agreement terms and the handling of transactions classify the applicant as an E-commerce operator responsible for tax collection at source under Section 52 of the CGST Act.
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