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...
GST Council's 53rd meeting recommendations led to amendments in Schedule III of CGST Act, clarifying two key insurance transactions. First, co-insurance premium apportionment by lead insurers to co-insurers is neither goods nor services supply, provided lead insurer pays all applicable taxes on full premium. Second, ceding/reinsurance commission deducted from reinsurance premium similarly excluded, conditional on reinsurer paying taxes on gross premium including commission. These changes, effective from 01.11.2024, also include retrospective regularization from 01.07.2017 to 31.10.2024 on 'as is where is' basis, resolving historical tax treatment ambiguities in insurance sector transactions.
GST Council's 53rd meeting recommendations led to amendments in Schedule III of CGST Act, clarifying two key insurance transactions. First, co-insurance premium apportionment by lead insurers to co-insurers is neither goods nor services supply, provided lead insurer pays all applicable taxes on full premium. Second, ceding/reinsurance commission deducted from reinsurance premium similarly excluded, conditional on reinsurer paying taxes on gross premium including commission. These changes, effective from 01.11.2024, also include retrospective regularization from 01.07.2017 to 31.10.2024 on 'as is where is' basis, resolving historical tax treatment ambiguities in insurance sector transactions.
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