Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Nature of transaction - supply of goods or transfer of property - work orders is required to fill in the foundation or plinth by silver sand in layers and consolidating the same by saturation with water ramming which also involves earth work for filling in the compound, tank, low land, ditches etc. It is, therefore, not a contract for the supply of goods, but the transfer of property in such goods in the course of preparing the site for construction - it is works contract, as defined u/s 2(119) and taxable @ 18%
Nature of transaction - supply of goods or transfer of property - work orders is required to fill in the foundation or plinth by silver sand in layers and consolidating the same by saturation with water ramming which also involves earth work for filling in the compound, tank, low land, ditches etc. It is, therefore, not a contract for the supply of goods, but the transfer of property in such goods in the course of preparing the site for construction - it is works contract, as defined u/s 2(119) and taxable @ 18%
Note: It is a system-generated summary and is for quick reference only.
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