Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The circular provides clarification on the place of supply for custodial services offered by banks to Foreign Portfolio Investors (FPIs). It addresses the confusion regarding whether these services fall under the category of services provided to 'account holders' as per Section 13(8)(a) of the IGST Act. The circular explains that custodial services do not qualify as services to account holders and should be determined under the default provision of sub-section (2) of section 13 of the IGST Act. This interpretation aligns with similar provisions in the Service Tax regime, indicating that custodial services are distinct from services provided to account holders. The circular emphasizes the need for uniformity in implementing these provisions across field formations.
The circular provides clarification on the place of supply for custodial services offered by banks to Foreign Portfolio Investors (FPIs). It addresses the confusion regarding whether these services fall under the category of services provided to 'account holders' as per Section 13(8)(a) of the IGST Act. The circular explains that custodial services do not qualify as services to account holders and should be determined under the default provision of sub-section (2) of section 13 of the IGST Act. This interpretation aligns with similar provisions in the Service Tax regime, indicating that custodial services are distinct from services provided to account holders. The circular emphasizes the need for uniformity in implementing these provisions across field formations.
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