Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Sub-rule (2) of Rule 28 of CGST Rules provides for valuation of supply of services of providing corporate guarantee between related persons. It applies to guarantees issued/renewed on or after 26.10.2023. Value is 1% of guaranteed amount per annum or actual consideration, whichever is higher. ITC is available irrespective of loan disbursal. No GST on takeover of existing loans unless fresh guarantee. For co-guarantors, value is sum of consideration or proportionate 1% of respective guaranteed amounts. Domestic guarantees under forward charge, overseas under reverse charge. Second proviso of sub-rule (1) applies. Export of such services excluded.
Sub-rule (2) of Rule 28 of CGST Rules provides for valuation of supply of services of providing corporate guarantee between related persons. It applies to guarantees issued/renewed on or after 26.10.2023. Value is 1% of guaranteed amount per annum or actual consideration, whichever is higher. ITC is available irrespective of loan disbursal. No GST on takeover of existing loans unless fresh guarantee. For co-guarantors, value is sum of consideration or proportionate 1% of respective guaranteed amounts. Domestic guarantees under forward charge, overseas under reverse charge. Second proviso of sub-rule (1) applies. Export of such services excluded.
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