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 ...
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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