Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Burial-ground upkeep and maintenance involving sweeping, cleaning and daily garbage collection is classified under SAC 999424 as general waste collection services, rather than a residuary service category. The municipal-function exemption under Entry 3A requires a composite supply of goods and services. Welfare kits, bins, tools, consumables and equipment used by the service provider to perform cleaning, without transfer of ownership or possession to the Corporation, do not constitute a supply of goods to the recipient. As the arrangement lacked the required composite supply, the Entry 3A exemption does not apply.
Burial-ground upkeep and maintenance involving sweeping, cleaning and daily garbage collection is classified under SAC 999424 as general waste collection services, rather than a residuary service category. The municipal-function exemption under Entry 3A requires a composite supply of goods and services. Welfare kits, bins, tools, consumables and equipment used by the service provider to perform cleaning, without transfer of ownership or possession to the Corporation, do not constitute a supply of goods to the recipient. As the arrangement lacked the required composite supply, the Entry 3A exemption does not apply.
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