Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Classification of supply - survey, designing, installation and commissioning of project under EPC contract - The AAAR held that the services provided by the appellant under the EPC contract are appropriately classifiable under SAC Heading No. 9954, answering to the description of "Construction Services," which are in the nature of composite supply defined as a works contract. The AAAR concluded that the proposed supplies specifically fall under SAC Heading No. 9954, rejecting the appellant's argument for a more specific classification under SAC Heading No. 998621 or Heading 9983.
Classification of supply - survey, designing, installation and commissioning of project under EPC contract - The AAAR held that the services provided by the appellant under the EPC contract are appropriately classifiable under SAC Heading No. 9954, answering to the description of "Construction Services," which are in the nature of composite supply defined as a works contract. The AAAR concluded that the proposed supplies specifically fall under SAC Heading No. 9954, rejecting the appellant's argument for a more specific classification under SAC Heading No. 998621 or Heading 9983.
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