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...
Taxability issues surrounding personal and corporate guarantees in the realm of Goods and Services Tax (GST). - The circular extends its clarification to corporate guarantees provided by one company for another related company or by a holding company for its subsidiary. These guarantees, too, are considered supplies of service between related persons under the HGST / GST Act, thereby attracting GST. It further specifies that the valuation of such supplies will follow Rule 28 of the HGST Rules, with a recent amendment introduced through Notification, to ensure uniformity in valuation practices.
Taxability issues surrounding personal and corporate guarantees in the realm of Goods and Services Tax (GST). - The circular extends its clarification to corporate guarantees provided by one company for another related company or by a holding company for its subsidiary. These guarantees, too, are considered supplies of service between related persons under the HGST / GST Act, thereby attracting GST. It further specifies that the valuation of such supplies will follow Rule 28 of the HGST Rules, with a recent amendment introduced through Notification, to ensure uniformity in valuation practices.
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