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...
Applicability: The waiver provisions u/s 128A apply to cases involving tax demands u/s 73 for financial years 2017-18, 2018-19, and 2019-20, and cases involving erroneous refunds. To avail the waiver, the full tax amount demanded must be paid by the notified date, excluding amounts no longer payable due to retrospective amendments to Section 16(5) and 16(6). Procedure: Applications for waiver must be filed in prescribed forms, and proper officers will examine eligibility. Notices may be issued, and applicants can file replies. Orders approving or rejecting waiver applications will be issued, with deemed approval if no order is passed within the time limit. Appeals against rejection orders are allowed. Payments: Amounts paid towards the demand before the notified date, including by tax officers recovering from other persons, are considered payments for eligibility. Interest/penalty amounts cannot be adjusted against tax dues. Partial payments do not qualify for waiver. ITC can be utilized for payment, except for reverse charge/e-commerce operator liabilities and erroneous refund demands. Clarifications: The circular provides clarifications on various issues, including applicability to IGST/Cess demands, transitional credit demands, penalties under other provisions, import IGST.
Applicability: The waiver provisions u/s 128A apply to cases involving tax demands u/s 73 for financial years 2017-18, 2018-19, and 2019-20, and cases involving erroneous refunds. To avail the waiver, the full tax amount demanded must be paid by the notified date, excluding amounts no longer payable due to retrospective amendments to Section 16(5) and 16(6). Procedure: Applications for waiver must be filed in prescribed forms, and proper officers will examine eligibility. Notices may be issued, and applicants can file replies. Orders approving or rejecting waiver applications will be issued, with deemed approval if no order is passed within the time limit. Appeals against rejection orders are allowed. Payments: Amounts paid towards the demand before the notified date, including by tax officers recovering from other persons, are considered payments for eligibility. Interest/penalty amounts cannot be adjusted against tax dues. Partial payments do not qualify for waiver. ITC can be utilized for payment, except for reverse charge/e-commerce operator liabilities and erroneous refund demands. Clarifications: The circular provides clarifications on various issues, including applicability to IGST/Cess demands, transitional credit demands, penalties under other provisions, import IGST.
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