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...
Exemption from GST - Educational institute or not - Seeking clarification as to whether the educational courses which are conducted by the 'Additional Skill Acquisition Programme Kerala' falls under the taxable service or not - The Authority for Advance Ruling evaluated ASAPK's status as an educational institution and the approval status of its vocational education courses. The Authority emphasized the requirement for registration with the Directorate General of Training, Ministry of Skill Development and Entrepreneurship, for availing exemption. Citing a Supreme Court ruling, the Authority stressed the strict interpretation of exemption notifications and the burden of proof on the assessee. Due to ambiguity and lack of supporting evidence, ASAPK's claim for exemption denied.
Exemption from GST - Educational institute or not - Seeking clarification as to whether the educational courses which are conducted by the 'Additional Skill Acquisition Programme Kerala' falls under the taxable service or not - The Authority for Advance Ruling evaluated ASAPK's status as an educational institution and the approval status of its vocational education courses. The Authority emphasized the requirement for registration with the Directorate General of Training, Ministry of Skill Development and Entrepreneurship, for availing exemption. Citing a Supreme Court ruling, the Authority stressed the strict interpretation of exemption notifications and the burden of proof on the assessee. Due to ambiguity and lack of supporting evidence, ASAPK's claim for exemption denied.
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