Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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