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...
CBIC clarified multiple GST applicability issues based on 55th GST Council recommendations. Key determinations: No GST payable on penal charges levied by regulated entities for loan contract breaches. GST exemption extended to RBI-regulated Payment Aggregators for settlements up to 2000 per transaction. Research and development services by Government Entities against grants regularized for period July 2017-October 2024. DDA not classified as local authority under GST law. GST applicable on facility management services to MCD headquarters. Training services by NSDC-approved partners exempted from January 2025, with past period regularized. Goethe Institute services' GST payments regularized for July 2017-March 2023 period.
CBIC clarified multiple GST applicability issues based on 55th GST Council recommendations. Key determinations: No GST payable on penal charges levied by regulated entities for loan contract breaches. GST exemption extended to RBI-regulated Payment Aggregators for settlements up to 2000 per transaction. Research and development services by Government Entities against grants regularized for period July 2017-October 2024. DDA not classified as local authority under GST law. GST applicable on facility management services to MCD headquarters. Training services by NSDC-approved partners exempted from January 2025, with past period regularized. Goethe Institute services' GST payments regularized for July 2017-March 2023 period.
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