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...
Department of Revenue issued notification exempting import of services by foreign airlines' Indian establishments from related parties/overseas establishments when made without consideration. Key conditions include: payment of applicable GST on transport services in India, MoCA certification of airline's designation under bilateral air service agreements, and reciprocal tax exemption for Indian airlines in the foreign country. MoCA provided a list of designated foreign airlines operating in Winter 2024-25 schedule and collected feedback from Indian carriers (Air India, IndiGo, Akasa Air) regarding reciprocal treatment. The notification stems from 54th GST Council recommendations and aims to establish tax parity in international aviation services while ensuring compliance with bilateral agreements.
Department of Revenue issued notification exempting import of services by foreign airlines' Indian establishments from related parties/overseas establishments when made without consideration. Key conditions include: payment of applicable GST on transport services in India, MoCA certification of airline's designation under bilateral air service agreements, and reciprocal tax exemption for Indian airlines in the foreign country. MoCA provided a list of designated foreign airlines operating in Winter 2024-25 schedule and collected feedback from Indian carriers (Air India, IndiGo, Akasa Air) regarding reciprocal treatment. The notification stems from 54th GST Council recommendations and aims to establish tax parity in international aviation services while ensuring compliance with bilateral agreements.
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