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 Delhi Department of Trade & Taxes adopted CBIC Circular No. 243/37/2024-GST clarifying GST treatment of vouchers under DGST Act, 2017. The CBIC determined that voucher transactions constitute neither supply of goods nor services, as vouchers qualify as either "money" under RBI-recognized pre-paid instruments or "actionable claims" under Schedule III exclusions. Principal-to-principal voucher trading by distributors remains non-taxable, while commission-based distribution services attract GST on fees received. Additional services like marketing and technology support provided to voucher issuers are taxable at applicable rates. Unredeemed vouchers (breakage) are not subject to GST as no underlying supply occurs and no consideration exists without express agreement for non-redemption charges.
The Delhi Department of Trade & Taxes adopted CBIC Circular No. 243/37/2024-GST clarifying GST treatment of vouchers under DGST Act, 2017. The CBIC determined that voucher transactions constitute neither supply of goods nor services, as vouchers qualify as either "money" under RBI-recognized pre-paid instruments or "actionable claims" under Schedule III exclusions. Principal-to-principal voucher trading by distributors remains non-taxable, while commission-based distribution services attract GST on fees received. Additional services like marketing and technology support provided to voucher issuers are taxable at applicable rates. Unredeemed vouchers (breakage) are not subject to GST as no underlying supply occurs and no consideration exists without express agreement for non-redemption charges.
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