Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
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