9911796707
TMI Blog2024 (8) TMI 986X X X X Extracts X X X X X X X X Extracts X X X X ..... (T-RES) - - X X X X Extracts X X X X X X X X Extracts X X X X ..... espective expats. 4. It is further submitted that during the period of employment with the petitioner salary was paid to them directly by the petitioner. It is further submitted that overseas group entity continued to provide social service benefits available at home country to the expats employees and the cost incurred in respect of such benefits is recovered as reimbursements from the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o. 210/4/2024-GST dated 26.06.2024 issued after the petition was filed reiterates clear position of law which if taken note of would result in show-cause notice being dropped to that extent. 8. Sri. K. Hema Kumar, learned AGA submits that the purport of Circular needs to be examined in the facts of the case and even otherwise, the applicability of the Circular requires adjudication and accordingl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e above, it is clarified that in cases where the foreign affiliate is providing certain services to the related domestic entity, and where full input tax credit is available to the said related domestic entity, the value of such supply of services declared in the invoice by the said related domestic entity may be deemed as open market value in terms of second proviso to rule 28 (1) of CGST Rules. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... racted above. Insofar as other points for consideration are concerned, no observation is made regarding the same and it is open to the authority to take considered decision regarding other contentions not referred to above. 11. With the above observations, the matter is relegated to the stage of reply to the show-cause notice. Needless to state the authorities concerned can take note of applicabi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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