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...
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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