Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer of title on invoicing to an Indian purchaser constitutes a taxable supply of goods between two persons in the taxable territory even though goods are sourced and remain outside India; consequently GST registration and tax payment are required under the governing supply provisions. Paragraph 7 of Schedule III (non-taxable territory-to-non-taxable territory supply) does not apply. Classification by HSN and applicable GST rate could not be determined for lack of product details; time and value of supply must be determined by the applicant under the statutory time/value rules. A request on transaction category was rejected as beyond advance ruling scope under section 97(2).
Transfer of title on invoicing to an Indian purchaser constitutes a taxable supply of goods between two persons in the taxable territory even though goods are sourced and remain outside India; consequently GST registration and tax payment are required under the governing supply provisions. Paragraph 7 of Schedule III (non-taxable territory-to-non-taxable territory supply) does not apply. Classification by HSN and applicable GST rate could not be determined for lack of product details; time and value of supply must be determined by the applicant under the statutory time/value rules. A request on transaction category was rejected as beyond advance ruling scope under section 97(2).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
