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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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