Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Taxability under GST - rent received from the Govt. SWCBH - pure services or not - The AAR analyzed the exemption clause of Notification No. 12/2017, which exempts pure services provided to government entities in relation to functions entrusted to municipalities under Article 243W of the Constitution of India. The AAR interpreted the phrase "in relation to" based on legal precedents and found that there must be a direct and immediate link between the services provided and the functions enumerated under Article 243W. - Accordingly, AAR held that, these services do not qualify for exemption under Notification No. 12/2017, making the rent received taxable.
Taxability under GST - rent received from the Govt. SWCBH - pure services or not - The AAR analyzed the exemption clause of Notification No. 12/2017, which exempts pure services provided to government entities in relation to functions entrusted to municipalities under Article 243W of the Constitution of India. The AAR interpreted the phrase "in relation to" based on legal precedents and found that there must be a direct and immediate link between the services provided and the functions enumerated under Article 243W. - Accordingly, AAR held that, these services do not qualify for exemption under Notification No. 12/2017, making the rent received taxable.
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