Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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