Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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