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Shivam Agrawal is a Chartered Accountant and AMU alumnus with a short but rich work experience in Indirect Taxation w.r.t. GST Implementation, GST Advisory & Compliance management and filing of GST refunds.

He is a keen learner actively involved in learning intricacies of Indirect tax and allied corporate laws including GST, Customs, SEZ, STP, FTP, FEMA and International Taxation with aim to grow as an Indirect Tax expert. He likes to research and write on topics relating to implications of tax laws and practical solutions for the industry challenges and has contributed various articles at Tax Management India and CAClubIndia.

He is currently working as Associate Manager in Corporate Taxation - GST Team at Infosys.

He can be reached out at [email protected] and will be happy to connect on LinkedIn @ https://www.linkedin.com/in/shivamagrawal535/

Showing 1 to 1 of 1 Results
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Issue Id: 119372
Dear Members, Please guide me on how to avail input tax credit of IGST paid through manual TR-6 Challans as duty on debonding of capital goods in ... Read Full Issue
Date 25 Oct 2024
Replies 3 Replies
Views 2987 Views
1 Reply on 1 Issue
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Issue Id: 119372
Dear Members, Please guide me on how to avail input tax credit of IGST paid through manual TR-6 Challans as duty on debonding of capital goods in ... Read Full Issue
Date 25 Oct 2024
Replies 1 Reply
Views 2987 Views
Showing 1 to 7 of 7 Results
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Tobacco and pan masala tax overhaul: RSP-based GST valuation, higher GST and revived excise from Feb 1, 2026.
From 1 February 2026 Rule 31D establishes RSP/MRP-based valuation for pan masala, most tobacco products and nicotine inhalation products (excluding bidis), requiring taxable value to be extracted from declared RSP; GST rates are restructured to 18% total for bidis and 40% total for pan masala and most other tobacco products, Compensation Cess is withdrawn, and central excise is reintroduced with a machine-capacity-based levy on pouched chewing tobacco/jarda/gutkha and substantially higher specific excise on cigarettes and cigars. (AI Summary)
Date 03 Jan 2026
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Permanent Establishment expansion under MLI narrows agency exemptions, increasing taxable presence exposure for cross-border businesses.
The document explains that Indian taxation depends on the nexus of residence and source: corporate residency via Place of Effective Management subjects companies to tax on global profits, while business connection, Significant Economic Presence and Permanent Establishment rules determine source-based taxation. Dependent agents who habitually conclude or play a principal role in contracts can create taxable connections or PE; independent agents generally do not. The MLI broadens dependent-agent PE and includes anti-fragmentation rules. The "make available" test governs whether software or services amount to royalty or FTS; mere use without transfer of know-how does not meet that test. (AI Summary)
Date 06 Aug 2025
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Service Permanent Establishment risks: secondment can create taxable presence with transfer pricing, DTAA relief and GST consequences.
Outward secondment arrangements implicate Service PE, Fees for Technical Services, transfer pricing and export of service GST treatment: a Service PE may arise where seconded employees remain deployed overseas and lien over employment remains with the Indian entity; FTS requires making available technical knowledge; resident Indian entities remain taxable on worldwide income subject to DTAA relief; reimbursements without markup are typically not taxable while markups received in India are taxable and require arm's length justification; GST export treatment depends on whether supplier and recipient are separate legal persons and whether IGST conditions are satisfied. (AI Summary)
Date 21 Mar 2025
Replies 1 Reply
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Royalty as consideration may prompt re-evaluation of GST exemption for excess royalty collection services, affecting compliance and notifications.
The Supreme Court's clarification that royalty is a consideration for the right to extract minerals, not a tax, affects GST treatment of services by Excess Royalty Collection Contractors (ERCC). This undermines the tax-like premise for the GST exemption under Notification No. 14/2018 Central Taxes (Rate), creating grounds for re-evaluation. Any removal or modification of the exemption would require a formal CBIC notification and is likely to be applied prospectively, while the judgment also affirms states' separate taxing powers over mineral rights and anticipates transitional measures for liabilities. (AI Summary)
Date 10 Mar 2025
Replies 3 Replies
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Time limit for self-invoice requires prompt issuance after receipt for supplies subject to reverse charge by registered recipients.
Rule 47A requires a registered person liable under reverse charge to issue the self-invoice within thirty days from the date of receipt of the supply of goods or services, implementing the Finance Act amendments that authorized a prescribed time-limit for self-invoicing and aligned self-invoice issuance with the revised time-of-supply rules for supplies from unregistered persons. (AI Summary)
Date 29 Oct 2024
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Value of supply in fixed rate foreign currency contracts: invoice in INR using prescribed exchange rate and bifurcate derivative impact.
Conversion to Indian rupees for GST requires applying Section 15 and Rule 34: goods use the Customs Board rate and services use the GAAP determined rate. Fixed rate contracts must be bifurcated into supply revenue recognised at the contracted forward rate and an embedded derivative representing the forex difference, which is outside GST and adjusted via financial credit/debit notes. Tax invoices must show the taxable value determined under these rules, and recipients may claim ITC as shown on the invoice subject to usual conditions. (AI Summary)
Date 28 Oct 2024
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Endorsement by SEZ specified officer required to support refund of unutilized input tax credit on services supplied to SEZs.
Refund of unutilized input tax credit for services supplied to a SEZ requires endorsement by the SEZ specified officer confirming receipt for authorised operations; to facilitate this, SEZ Online introduced the DTA Service Procurement Form (DSPF) module enabling SEZ units to upload multiple service invoices, submit them electronically for Authorised/Specified Officer endorsement, and generate acknowledgements to DTA suppliers to support refund applications for zero rated supplies. (AI Summary)
Date 26 Oct 2024
Shivam Agrawal
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May 2024