Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
AAR admitted a registered recipient's advance ruling application, relying on Calcutta HC authority that a registered person can seek ruling on merits. It held that the temple's grant of licence to collect human hair from its premises was a separate commercial arrangement, distinct from devotees' religious tonsuring, and constituted a supply of service under GST because the temple transferred a right for consideration in the course of business. The exemption for human hair as goods did not apply because the transaction was not a sale of goods but a licensed service. The question whether the temple was business premises was not answered as it fell outside the limited scope of advance ruling jurisdiction.
AAR admitted a registered recipient's advance ruling application, relying on Calcutta HC authority that a registered person can seek ruling on merits. It held that the temple's grant of licence to collect human hair from its premises was a separate commercial arrangement, distinct from devotees' religious tonsuring, and constituted a supply of service under GST because the temple transferred a right for consideration in the course of business. The exemption for human hair as goods did not apply because the transaction was not a sale of goods but a licensed service. The question whether the temple was business premises was not answered as it fell outside the limited scope of advance ruling jurisdiction.
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