Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Guarantee commission paid by a State undertaking to the State government for guarantees on bonds falls within the exemption under Entry No. 34A of Notification No. 12/2017-Central Tax (Rate), as amended, and is therefore not subject to GST. The Authority relied on the statutory entry's language and the CBIC clarification (Circular No. 154/10/2021) to construe the scope of exempted services, concluding that consideration received by the State for guaranteeing loans or debentures qualifies for exemption; consequently the commission payable for the guarantees is exempt from GST.
Guarantee commission paid by a State undertaking to the State government for guarantees on bonds falls within the exemption under Entry No. 34A of Notification No. 12/2017-Central Tax (Rate), as amended, and is therefore not subject to GST. The Authority relied on the statutory entry's language and the CBIC clarification (Circular No. 154/10/2021) to construe the scope of exempted services, concluding that consideration received by the State for guaranteeing loans or debentures qualifies for exemption; consequently the commission payable for the guarantees is exempt from GST.
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