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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A recent circular addressed the taxability of loans between related parties or affiliates. The circular clarifies that providing loans between related parties constitutes a taxable supply under GST. However, services involving interest or discount on loans are fully exempt. Processing fees or administrative charges on loans may be subject to GST, but in cases where no such fees are charged, no GST applies. Fees charged by lenders to related parties beyond interest or discount are considered taxable. The circular emphasizes the distinction between loans provided by related parties and independent lenders, noting differences in processing requirements. It advises issuing trade notices to disseminate the circular's contents and invites feedback on implementation challenges.
A recent circular addressed the taxability of loans between related parties or affiliates. The circular clarifies that providing loans between related parties constitutes a taxable supply under GST. However, services involving interest or discount on loans are fully exempt. Processing fees or administrative charges on loans may be subject to GST, but in cases where no such fees are charged, no GST applies. Fees charged by lenders to related parties beyond interest or discount are considered taxable. The circular emphasizes the distinction between loans provided by related parties and independent lenders, noting differences in processing requirements. It advises issuing trade notices to disseminate the circular's contents and invites feedback on implementation challenges.
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