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...
The APGST circular addresses multiple GST-related clarifications following the 55th GST Council meeting. Key outcomes include: (1) No GST on penal charges levied by Regulated Entities per RBI instructions, (2) GST exemption confirmed for Payment Aggregators settling transactions up to 2,000, (3) Regularization of GST payment for research and development services from 2017-2024, (4) Restoration of GST exemption for NSDC-approved Training Partners, (5) Regularization of GST on commercial property rental under Reverse Charge Mechanism for composition levy taxpayers, and (6) Regularization of GST on incidental electricity transmission and distribution utility services from October 2024 to January 2025, all implemented on an 'as is where is' basis.
The APGST circular addresses multiple GST-related clarifications following the 55th GST Council meeting. Key outcomes include: (1) No GST on penal charges levied by Regulated Entities per RBI instructions, (2) GST exemption confirmed for Payment Aggregators settling transactions up to 2,000, (3) Regularization of GST payment for research and development services from 2017-2024, (4) Restoration of GST exemption for NSDC-approved Training Partners, (5) Regularization of GST on commercial property rental under Reverse Charge Mechanism for composition levy taxpayers, and (6) Regularization of GST on incidental electricity transmission and distribution utility services from October 2024 to January 2025, all implemented on an 'as is where is' basis.
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