Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Entry 23A of Notification No. 12/2017 exempts services of providing access to a road or bridge against annuity under Heading 9967; it does not exempt road construction, design, operation and maintenance supplied as works-contract services under Heading 9954. Deferred annuity payments under a road concession agreement may therefore constitute taxable consideration where they represent the unpaid balance of project costs. Clarificatory circulars may state the applicable statutory position and guide implementation. Taxability depends on the notification and the actual nature of the supply, while an earlier advance ruling based on an erroneous understanding does not bind implementing authorities after legal clarification.
Entry 23A of Notification No. 12/2017 exempts services of providing access to a road or bridge against annuity under Heading 9967; it does not exempt road construction, design, operation and maintenance supplied as works-contract services under Heading 9954. Deferred annuity payments under a road concession agreement may therefore constitute taxable consideration where they represent the unpaid balance of project costs. Clarificatory circulars may state the applicable statutory position and guide implementation. Taxability depends on the notification and the actual nature of the supply, while an earlier advance ruling based on an erroneous understanding does not bind implementing authorities after legal clarification.
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