Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Transfer of ESOP/ESPP/RSU by foreign holding company to employees of domestic subsidiary company does not attract GST where no additional fee, markup or commission is charged. Securities/shares are neither goods nor services under GST law. Reimbursement by domestic subsidiary to foreign holding company on cost-to-cost basis for transfer of securities/shares is not import of services. However, if foreign holding company charges additional amount over cost for facilitating/arranging transaction, GST is leviable on such additional amount payable by domestic subsidiary on reverse charge basis as import of services.
Transfer of ESOP/ESPP/RSU by foreign holding company to employees of domestic subsidiary company does not attract GST where no additional fee, markup or commission is charged. Securities/shares are neither goods nor services under GST law. Reimbursement by domestic subsidiary to foreign holding company on cost-to-cost basis for transfer of securities/shares is not import of services. However, if foreign holding company charges additional amount over cost for facilitating/arranging transaction, GST is leviable on such additional amount payable by domestic subsidiary on reverse charge basis as import of services.
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