Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Taxability of Personal Guarantee and Corporate Guarantee in GST - Corporate Guarantees provided by a holding company to its subsidiary under the Central Goods & Service Tax Act, 2017. The petitioner sought a declaration that such activity does not constitute a taxable supply of services. Arguments were presented regarding the validity of a Circular issued by the Central Board of Indirect Taxes & Customs, interpretation of previous legal precedents, the impact of recent amendments, and the nature of Corporate Guarantees as contingent contracts. The High Court allowed time for further submissions from both parties and directed no coercive action against the petitioner until further proceedings. - Matter listed for next date.
Taxability of Personal Guarantee and Corporate Guarantee in GST - Corporate Guarantees provided by a holding company to its subsidiary under the Central Goods & Service Tax Act, 2017. The petitioner sought a declaration that such activity does not constitute a taxable supply of services. Arguments were presented regarding the validity of a Circular issued by the Central Board of Indirect Taxes & Customs, interpretation of previous legal precedents, the impact of recent amendments, and the nature of Corporate Guarantees as contingent contracts. The High Court allowed time for further submissions from both parties and directed no coercive action against the petitioner until further proceedings. - Matter listed for next date.
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