Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Solar inverters supplied for use in solar power generating systems were treated as integral parts of that system and, on the material produced, fell within Sl. No. 234 of Notification No. 1/2017-CT(R), attracting GST at 5%. The Court held that the concession extends to parts used for manufacture of solar power generating systems, and that assembling such parts into a new product with a distinct name, character and use satisfies the definition of manufacture. It also held that expressions such as "required to manufacture" and "for use" refer to intended use, so proof of actual end-use was not necessary. The contrary orders were quashed to that extent.
Solar inverters supplied for use in solar power generating systems were treated as integral parts of that system and, on the material produced, fell within Sl. No. 234 of Notification No. 1/2017-CT(R), attracting GST at 5%. The Court held that the concession extends to parts used for manufacture of solar power generating systems, and that assembling such parts into a new product with a distinct name, character and use satisfies the definition of manufacture. It also held that expressions such as "required to manufacture" and "for use" refer to intended use, so proof of actual end-use was not necessary. The contrary orders were quashed to that extent.
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