Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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This circular clarifies various issues related to taxability and valuation of supply of services involving corporate guarantees provided between related persons. It covers applicability of Rule 28(2) of CGST Rules retrospectively, valuation methodologies based on amount guaranteed or actual consideration, treatment of partial loan disbursals, takeovers, co-guarantors, reverse charge mechanism for foreign guarantors, periodicity of valuation, benefit of value declared in invoice, and exclusion of exports from Rule 28(2). The circular aims to ensure uniform implementation across field formations.
This circular clarifies various issues related to taxability and valuation of supply of services involving corporate guarantees provided between related persons. It covers applicability of Rule 28(2) of CGST Rules retrospectively, valuation methodologies based on amount guaranteed or actual consideration, treatment of partial loan disbursals, takeovers, co-guarantors, reverse charge mechanism for foreign guarantors, periodicity of valuation, benefit of value declared in invoice, and exclusion of exports from Rule 28(2). The circular aims to ensure uniform implementation across field formations.
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