Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Circular clarifies GST treatment of secondary/post-sale discounts: when suppliers issue financial/commercial credit notes that do not reduce the original transaction value, recipients need not reverse input tax credit as the supplier's tax liability remains unchanged. Post-sale discounts from a manufacturer to a dealer are generally viewed as price reductions between independent sales (manufacturer→dealer; dealer→customer) and are not treated as consideration for inducement of the dealer's supply, unless the manufacturer has a direct agreement with the end customer-then such discounts should be included in overall consideration. Discounts are not consideration for promotional services unless a separate agreement specifies distinct services and consideration.
Circular clarifies GST treatment of secondary/post-sale discounts: when suppliers issue financial/commercial credit notes that do not reduce the original transaction value, recipients need not reverse input tax credit as the supplier's tax liability remains unchanged. Post-sale discounts from a manufacturer to a dealer are generally viewed as price reductions between independent sales (manufacturer→dealer; dealer→customer) and are not treated as consideration for inducement of the dealer's supply, unless the manufacturer has a direct agreement with the end customer-then such discounts should be included in overall consideration. Discounts are not consideration for promotional services unless a separate agreement specifies distinct services and consideration.
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