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...
The Tribunal interpreted Sl. No. 226 of Notification No. 1/2017-Integrated Tax (Rate) on a plain reading of the words "LED lights or fixtures including LED lamps" and held that "including" is a word of enlargement, not restriction. It rejected the narrower construction that would confine the benefit only to fixtures fitted with or containing LED lamps. On that interpretation, imported lighting fixtures were held eligible for the concessional rate, and the demand, interest and penalty raised on denial of the notification benefit were set aside.
The Tribunal interpreted Sl. No. 226 of Notification No. 1/2017-Integrated Tax (Rate) on a plain reading of the words "LED lights or fixtures including LED lamps" and held that "including" is a word of enlargement, not restriction. It rejected the narrower construction that would confine the benefit only to fixtures fitted with or containing LED lamps. On that interpretation, imported lighting fixtures were held eligible for the concessional rate, and the demand, interest and penalty raised on denial of the notification benefit were set aside.
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