Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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