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...
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
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