Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ECOs liable for tax under Sec 9(5) of WBGST Act are not required to reverse input tax credit on inputs and input services proportionately for specified services supplied through their platforms. While ECOs must pay full tax liability for Sec 9(5) supplies through electronic cash ledger only, they can utilize their ITC for tax obligations on their own account services like platform fees. The clarification extends the principle previously established for restaurant services to all specified services under Sec 9(5). ECOs operate in dual capacity - as deemed suppliers for notified services and as platform service providers charging commission. Their ITC remains valid for platform operations but cannot offset Sec 9(5) tax liabilities.
ECOs liable for tax under Sec 9(5) of WBGST Act are not required to reverse input tax credit on inputs and input services proportionately for specified services supplied through their platforms. While ECOs must pay full tax liability for Sec 9(5) supplies through electronic cash ledger only, they can utilize their ITC for tax obligations on their own account services like platform fees. The clarification extends the principle previously established for restaurant services to all specified services under Sec 9(5). ECOs operate in dual capacity - as deemed suppliers for notified services and as platform service providers charging commission. Their ITC remains valid for platform operations but cannot offset Sec 9(5) tax liabilities.
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