Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
HC determined the maintainability of petition challenging show cause notice under Section 74 of CGST Act regarding taxation of reward amounts received from Hong Kong group company. Court rejected preliminary objection, noting dual taxation attempt by Maharashtra and Karnataka authorities on same Rs. 6092 Crores transaction. Karnataka HC had already stayed notice for full amount, while Maharashtra sought to tax a portion. Given significant legal questions and Rs. 75 crores already deposited with Maharashtra authorities, court restrained respondents from further action on show cause notice dated July 21, 2024. Key consideration was prevention of double taxation on identical transaction across jurisdictions.
HC determined the maintainability of petition challenging show cause notice under Section 74 of CGST Act regarding taxation of reward amounts received from Hong Kong group company. Court rejected preliminary objection, noting dual taxation attempt by Maharashtra and Karnataka authorities on same Rs. 6092 Crores transaction. Karnataka HC had already stayed notice for full amount, while Maharashtra sought to tax a portion. Given significant legal questions and Rs. 75 crores already deposited with Maharashtra authorities, court restrained respondents from further action on show cause notice dated July 21, 2024. Key consideration was prevention of double taxation on identical transaction across jurisdictions.
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