Tax & Regulatory Newsletter – December, 2019 Edition
Greetings!
We are pleased to attach herewith the Tax & Regulatory Newsletter – December, 2019 edition highlighting major recent tax and regulatory developments.
Inside this issue…
DIRECT TAX
ITAT Delhi: Hitachi Singapore’s Liaison Office constitutes PE in India
Link charges and shrink wrapped software not ‘Royalty’; associated service fees not ‘FTS’ under the India-USA tax treaty
Bandwidth charges not taxable as Royalty under the India-Singapore tax treaty
FTC available in respect of foreign taxes paid overseas even if the income is not subjected to tax in India
TRANSFER PRICING
ITAT deletes adjustment on outstanding receivables sans existence of international transaction entered into between two domestic AEs; reiterates that SDT provisions inapplicable prior to 2012
ITAT adopts cup method, accept comparable data from the custom department’s database for benchmarking imports/exports
REGULATORY
Recent regulatory amendments impacting companies doing business in India
GST
Restriction in availment of input tax credit (ITC) in respect of invoices or debit notes, the details of which have not been uploaded by the suppliers
Simplification of GSTR-9 (Annual Return) and GSTR-9C (Audit Report) for Financial Year (‘FY’) 2017-18 and FY 2018-19
COMPLIANCE CALENDAR
Direct Tax
GST
Regulatory
We trust that you will find it interesting and informative.
Nangia Andersen India Pvt. Ltd. – Tax & Regulatory Newsletter – December, 2019 Edition