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...
State tax authority adopts central GST Policy Wing circular to clarify treatment of secondary/post-sale discounts. Financial or commercial credit notes do not reduce the original transaction value, so recipients need not reverse input tax credit. Post-sale discounts from a manufacturer to a dealer are generally treated as price reductions and not as consideration for the dealer's supply to end customers, unless there is an agreement between manufacturer and end customer making the discount an inducement; such discounts must be included in overall consideration in that case. Discounts are not consideration for separate services unless specific, agreed promotional services with defined consideration are provided.
State tax authority adopts central GST Policy Wing circular to clarify treatment of secondary/post-sale discounts. Financial or commercial credit notes do not reduce the original transaction value, so recipients need not reverse input tax credit. Post-sale discounts from a manufacturer to a dealer are generally treated as price reductions and not as consideration for the dealer's supply to end customers, unless there is an agreement between manufacturer and end customer making the discount an inducement; such discounts must be included in overall consideration in that case. Discounts are not consideration for separate services unless specific, agreed promotional services with defined consideration are provided.
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