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. 242/36/2024 clarifying place of supply rules for online services to unregistered recipients under GST. The circular mandates that suppliers providing online services, OIDAR services, or services through e-commerce operators to unregistered recipients must record the recipient's state name on tax invoices regardless of supply value. This recorded state name constitutes the address on record, making the recipient's location the place of supply under Section 12(2)(b)(i) of IGST Act. The clarification extends beyond OIDAR services to cover all online/digital services including OTT subscriptions, e-newspapers, and mobile app services. Non-compliance with mandatory invoice particulars may attract penalties under Section 122(3)(e) of CGST Act. Suppliers must establish mechanisms to collect recipient state details before service provision.
The Delhi Department of Trade & Taxes adopted CBIC Circular No. 242/36/2024 clarifying place of supply rules for online services to unregistered recipients under GST. The circular mandates that suppliers providing online services, OIDAR services, or services through e-commerce operators to unregistered recipients must record the recipient's state name on tax invoices regardless of supply value. This recorded state name constitutes the address on record, making the recipient's location the place of supply under Section 12(2)(b)(i) of IGST Act. The clarification extends beyond OIDAR services to cover all online/digital services including OTT subscriptions, e-newspapers, and mobile app services. Non-compliance with mandatory invoice particulars may attract penalties under Section 122(3)(e) of CGST Act. Suppliers must establish mechanisms to collect recipient state details before service provision.
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