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...
E-rickshaw supplies in CKD/SKD form qualify for GST treatment as the finished electrically operated vehicle only when all components needed to assemble a complete vehicle are supplied together as one identifiable kit or package, and the consignment contents and contemporaneous commercial records consistently match that description. The AAAR rejected the motor-plus-three-components test because it does not arise from Rule 2(a), the tariff, or the rate notification, and held that individual parts cannot be classified as the finished vehicle merely because some are essential components. It also noted that customs interpretative fiction under Rule 2(a) has a limited scope and cannot be extended beyond customs classification.
E-rickshaw supplies in CKD/SKD form qualify for GST treatment as the finished electrically operated vehicle only when all components needed to assemble a complete vehicle are supplied together as one identifiable kit or package, and the consignment contents and contemporaneous commercial records consistently match that description. The AAAR rejected the motor-plus-three-components test because it does not arise from Rule 2(a), the tariff, or the rate notification, and held that individual parts cannot be classified as the finished vehicle merely because some are essential components. It also noted that customs interpretative fiction under Rule 2(a) has a limited scope and cannot be extended beyond customs classification.
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