Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
TP Adjustment - The product licenses were held by the AE who was also responsible for maintenance of the product licenses. The manufacturing was done in strict adherence to Product License and the labeling on products was of assessee’s AE. The same is evident from Technical agreement (page no. 342-356 of the Paper Book) between the assessee and FDC-UK (AE). In case of non-AE sales, these expenses are to be borne by the assessee, which fact remains undisputed before us. Therefore, the adjustment of this component has rightly been allowed by Ld. CIT(A). - AT
TP Adjustment - The product licenses were held by the AE who was also responsible for maintenance of the product licenses. The manufacturing was done in strict adherence to Product License and the labeling on products was of assessee’s AE. The same is evident from Technical agreement (page no. 342-356 of the Paper Book) between the assessee and FDC-UK (AE). In case of non-AE sales, these expenses are to be borne by the assessee, which fact remains undisputed before us. Therefore, the adjustment of this component has rightly been allowed by Ld. CIT(A). - AT
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