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...
Clarifies that in cases of import of services by a registered person in India from a related person located outside India, where the recipient is eligible for full input tax credit, the value declared in the invoice by the recipient shall be deemed as open market value as per the second proviso to Rule 28(1) of KGST Rules. Further, if no invoice is issued by the recipient for services provided by the foreign affiliate, the value may be deemed as Nil and treated as open market value under the same provision. Directs trade notices to publicize the circular and address implementation difficulties.
Clarifies that in cases of import of services by a registered person in India from a related person located outside India, where the recipient is eligible for full input tax credit, the value declared in the invoice by the recipient shall be deemed as open market value as per the second proviso to Rule 28(1) of KGST Rules. Further, if no invoice is issued by the recipient for services provided by the foreign affiliate, the value may be deemed as Nil and treated as open market value under the same provision. Directs trade notices to publicize the circular and address implementation difficulties.
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