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 ...
GST is payable under reverse charge mechanism on issuance of corporate guarantee without consideration by foreign group company to Indian subsidiary for loan taken from banks/financial institutions. The time of supply is the date of entry in books of Indian recipient. Prior to 26.10.2023, GST is payable at the time of execution based on valuation u/r 28(1). Post 26.10.2023, GST is payable one-time at 1% of total loan value u/r 28(2) at the time of execution. For continuing guarantees spanning multiple years, the value needs to be divided equally among relevant years, with GST payable at 1% of such divided value for the first year and 1% of outstanding loan value for subsequent years u/r 28(2).
GST is payable under reverse charge mechanism on issuance of corporate guarantee without consideration by foreign group company to Indian subsidiary for loan taken from banks/financial institutions. The time of supply is the date of entry in books of Indian recipient. Prior to 26.10.2023, GST is payable at the time of execution based on valuation u/r 28(1). Post 26.10.2023, GST is payable one-time at 1% of total loan value u/r 28(2) at the time of execution. For continuing guarantees spanning multiple years, the value needs to be divided equally among relevant years, with GST payable at 1% of such divided value for the first year and 1% of outstanding loan value for subsequent years u/r 28(2).
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