Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The HC allowed the petition and granted retrospective relief: the O-in-O dated 29 Dec 2023 and the O-in-A dated 11 Jul 2024 are set aside insofar as they denied the petitioner the benefit of Circular No. 228/22/2024-GST dated 15 Jul 2024. The court held that, although those orders were rendered before issuance of the circular, the petitioner cannot be deprived of its benefit for the levy of GST on reinsurance of specified general and life insurance schemes for the period 01 Jul 2017 to 24 Jan 2018. The circular is declared squarely applicable to the petitioner and the decision in AXA France Vie-India is held to be applicable. Petition disposed.
The HC allowed the petition and granted retrospective relief: the O-in-O dated 29 Dec 2023 and the O-in-A dated 11 Jul 2024 are set aside insofar as they denied the petitioner the benefit of Circular No. 228/22/2024-GST dated 15 Jul 2024. The court held that, although those orders were rendered before issuance of the circular, the petitioner cannot be deprived of its benefit for the levy of GST on reinsurance of specified general and life insurance schemes for the period 01 Jul 2017 to 24 Jan 2018. The circular is declared squarely applicable to the petitioner and the decision in AXA France Vie-India is held to be applicable. Petition disposed.
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