Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Services rendered by an authorised service provider under Telangana's electronic service delivery framework were treated as distinct from supplies by the State Government. The Authority found that MeeSeva collects user charges over and above statutory fees, and that some services also relate to non-government entities. It therefore concluded that the exemption entries in Notification No. 12/2017-Central Tax (Rate) apply only to Government supplies and only to the extent of statutory levies for discharge of statutory functions. User charges collected separately by MeeSeva were held outside the exemption and liable to GST, so the exemption claim was rejected.
Services rendered by an authorised service provider under Telangana's electronic service delivery framework were treated as distinct from supplies by the State Government. The Authority found that MeeSeva collects user charges over and above statutory fees, and that some services also relate to non-government entities. It therefore concluded that the exemption entries in Notification No. 12/2017-Central Tax (Rate) apply only to Government supplies and only to the extent of statutory levies for discharge of statutory functions. User charges collected separately by MeeSeva were held outside the exemption and liable to GST, so the exemption claim was rejected.
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