Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Clinical trial and related R&D services supplied to a foreign recipient raised the issue whether the place of supply was outside India, making the supply an export and not liable to GST, and whether Notification No. 04/2019-IGST dated 30.09.2019 applied retrospectively to the period April 2018-March 2019. The notification clarified that for such services the place of supply is the location of the recipient, subject to conditions; since the recipient was located in the USA, the supply fell in a non-taxable territory. Treating the notification as beneficial, clarificatory and elucidatory, it was held to operate retrospectively, and the contrary view of the authorities was erroneous; the impugned orders were set aside and the petition was allowed - HC
Clinical trial and related R&D services supplied to a foreign recipient raised the issue whether the place of supply was outside India, making the supply an export and not liable to GST, and whether Notification No. 04/2019-IGST dated 30.09.2019 applied retrospectively to the period April 2018-March 2019. The notification clarified that for such services the place of supply is the location of the recipient, subject to conditions; since the recipient was located in the USA, the supply fell in a non-taxable territory. Treating the notification as beneficial, clarificatory and elucidatory, it was held to operate retrospectively, and the contrary view of the authorities was erroneous; the impugned orders were set aside and the petition was allowed - HC
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