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...
Clarification on TCS liability under section 52 of the DGST Act, 2017 in case of multiple E-commerce Operators in one transaction - The circular clarifies the TCS liability under section 52 of the DGST Act concerning transactions involving multiple ECOs. It distinguishes between scenarios where the supplier-side ECO is and isn't the direct supplier, attributing TCS compliance to the entity responsible for remitting payment to the supplier. In cases where the supplier-side ECO acts solely as a facilitator, it bears the TCS burden, whereas, when the supplier-side ECO is also the supplier, the buyer-side ECO assumes TCS collection responsibilities.
Clarification on TCS liability under section 52 of the DGST Act, 2017 in case of multiple E-commerce Operators in one transaction - The circular clarifies the TCS liability under section 52 of the DGST Act concerning transactions involving multiple ECOs. It distinguishes between scenarios where the supplier-side ECO is and isn't the direct supplier, attributing TCS compliance to the entity responsible for remitting payment to the supplier. In cases where the supplier-side ECO acts solely as a facilitator, it bears the TCS burden, whereas, when the supplier-side ECO is also the supplier, the buyer-side ECO assumes TCS collection responsibilities.
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