Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
ICT@ Schools services were treated as one naturally bundled composite supply, with infrastructure, software, maintenance, teacher training and student instruction forming an integrated education service under the BOOT model. Applying the predominant nature test, the Tribunal held that the ICT platform was only the medium for delivering curriculum-based computer education in schools, so the services fell within the education exemption under the negative list up to 13.05.2016 and continued to be exempt under the amended Mega Exemption Notification thereafter. Because the activities were not taxable during the disputed period, the valuation and abatement objections were academic, and the Revenue's challenge was held not maintainable.
ICT@ Schools services were treated as one naturally bundled composite supply, with infrastructure, software, maintenance, teacher training and student instruction forming an integrated education service under the BOOT model. Applying the predominant nature test, the Tribunal held that the ICT platform was only the medium for delivering curriculum-based computer education in schools, so the services fell within the education exemption under the negative list up to 13.05.2016 and continued to be exempt under the amended Mega Exemption Notification thereafter. Because the activities were not taxable during the disputed period, the valuation and abatement objections were academic, and the Revenue's challenge was held not maintainable.
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