Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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%
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