Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Passenger transportation follows the place of embarkation for a continuous journey. Where either the supplier or passenger is outside India, a short transit stop does not amount to a stopover or interrupt the journey; transportation embarking outside India consequently has a place of supply outside India and is not subject to GST. Where both supplier and passenger are in India, embarkation from Kolkata makes the service an intra-State supply liable to CGST and WBGST at the notified rate, with economy-class treatment subject to the input tax credit condition. Air transportation of human remains falls within funeral, burial, crematorium or mortuary services and is neither a supply of goods nor services, so remains outside GST.
Passenger transportation follows the place of embarkation for a continuous journey. Where either the supplier or passenger is outside India, a short transit stop does not amount to a stopover or interrupt the journey; transportation embarking outside India consequently has a place of supply outside India and is not subject to GST. Where both supplier and passenger are in India, embarkation from Kolkata makes the service an intra-State supply liable to CGST and WBGST at the notified rate, with economy-class treatment subject to the input tax credit condition. Air transportation of human remains falls within funeral, burial, crematorium or mortuary services and is neither a supply of goods nor services, so remains outside GST.
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