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...
Assignment of the right to collect royalty by a State to a...
Reverse charge and assignment of royalty collection: exemption for excess royalty collectors subject to reconciliation; leaseholders remain liable under RCM
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Assignment of the right to collect royalty by a State to a contractor is treated as a taxable licensing service, but Entry 65B in Notification No.12/2017 (as amended) exempts services to Excess Royalty Collection Contractors (ERCC) subject to reconciliation and end of contract certification; consequence: ERCCs obtain conditional exemption on the assigned right fees. Separately, statutory levies (royalty, seigniorage, DMF, MERIT) remain taxable under the Reverse Charge Mechanism and are payable by the quarry/mining leaseholders; consequence: ERCCs collect and remit these amounts but do not bear GST on them, although ERCCs must pay GST on collection/agency services they provide to the Government.
Assignment of the right to collect royalty by a State to a contractor is treated as a taxable licensing service, but Entry 65B in Notification No.12/2017 (as amended) exempts services to Excess Royalty Collection Contractors (ERCC) subject to reconciliation and end of contract certification; consequence: ERCCs obtain conditional exemption on the assigned right fees. Separately, statutory levies (royalty, seigniorage, DMF, MERIT) remain taxable under the Reverse Charge Mechanism and are payable by the quarry/mining leaseholders; consequence: ERCCs collect and remit these amounts but do not bear GST on them, although ERCCs must pay GST on collection/agency services they provide to the Government.
Note: It is a system-generated summary and is for quick reference only.