Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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