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...
DSCL qualified as a Governmental Authority because it was a government-established special purpose vehicle with 90% or more governmental equity/control and was set up to implement urban local body functions. Its services for the Smart City/ESCO water-supply project to UJS were exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate) because water supply is a Twelfth Schedule municipal function. The question whether the tripartite arrangement created two distinct supplies was held not maintainable within the questions raised. DSCL was also held not to be a pure agent under Rule 33, so the contractor-related amounts formed part of the value of supply.
DSCL qualified as a Governmental Authority because it was a government-established special purpose vehicle with 90% or more governmental equity/control and was set up to implement urban local body functions. Its services for the Smart City/ESCO water-supply project to UJS were exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate) because water supply is a Twelfth Schedule municipal function. The question whether the tripartite arrangement created two distinct supplies was held not maintainable within the questions raised. DSCL was also held not to be a pure agent under Rule 33, so the contractor-related amounts formed part of the value of supply.
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