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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether installation and commissioning charges for packing and wrapping machinery are includible in the assessable value.
Analysis: The charges in question related to services rendered after manufacture and clearance of the machinery. The factual basis for inclusion on the footing of manufacture or additional consideration was rejected, and the precedent relied upon by the Revenue was distinguished as involving a different question concerning marketability of plant and machinery embedded at site.
Conclusion: Installation and commissioning charges are not includible in the assessable value of the packing and wrapping machinery, and the Revenue's appeal fails.
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