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...
The Appellate Authority for Advance Ruling (AAAR) rejected the classification under SAC Heading 9986 (support services to oil and gas extraction) and SAC Heading 9983 (other professional, technical, and business services relating to exploration, mining, or drilling of petroleum crude or natural gas) as proposed by the Appellant. Instead, it was held that the services provided under the EPC contract fall under SAC Heading 9954, related to construction services, and are thus taxable at 18%. The reasoning was based on the nature of the contract which encompasses comprehensive activities including surveying, designing, installation, commissioning, and handing over of a functional project, indicating the creation of an immovable property, characteristic of construction services. - Given the classification under SAC Heading 9954, the services are subject to GST at 18%.
The Appellate Authority for Advance Ruling (AAAR) rejected the classification under SAC Heading 9986 (support services to oil and gas extraction) and SAC Heading 9983 (other professional, technical, and business services relating to exploration, mining, or drilling of petroleum crude or natural gas) as proposed by the Appellant. Instead, it was held that the services provided under the EPC contract fall under SAC Heading 9954, related to construction services, and are thus taxable at 18%. The reasoning was based on the nature of the contract which encompasses comprehensive activities including surveying, designing, installation, commissioning, and handing over of a functional project, indicating the creation of an immovable property, characteristic of construction services. - Given the classification under SAC Heading 9954, the services are subject to GST at 18%.
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