Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Construction services supplied to the identified statutory...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on remand.
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Construction services supplied to the identified statutory bodies qualified for exemption as services provided to governmental authorities because each recipient was created under statute. Denial of exemption to some recipients without reasons, despite acceptance for others with the same status, was set aside. For works-contract exemption applicable from 1 March 2016, the contract had to be entered into before 1 March 2015 and applicable stamp duty paid before that date. Documents subsequently produced to establish compliance required verification, so the affected contracts were remitted for de novo adjudication after allowing reasonable opportunity.
Construction services supplied to the identified statutory bodies qualified for exemption as services provided to governmental authorities because each recipient was created under statute. Denial of exemption to some recipients without reasons, despite acceptance for others with the same status, was set aside. For works-contract exemption applicable from 1 March 2016, the contract had to be entered into before 1 March 2015 and applicable stamp duty paid before that date. Documents subsequently produced to establish compliance required verification, so the affected contracts were remitted for de novo adjudication after allowing reasonable opportunity.
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