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...
The Advance Ruling Authority (ARA) addressed the interpretation of the expression "parts of goods of headings 8901, 8902, 8904, 8905, 8906, 8907" in specific notifications. The key issue was whether the goods/spares used were parts of warships/submarines. The ARA held that essential components like engines, gearbox, propeller, etc., are integral parts of a ship/vessel based on definitions of "part." Goods qualifying as parts of specific headings attract GST under the relevant notification. Items listed in Annexure 2A were deemed essential parts of a warship/submarine and subject to specific GST rates, while others in different annexures were not covered under the said notification.
The Advance Ruling Authority (ARA) addressed the interpretation of the expression "parts of goods of headings 8901, 8902, 8904, 8905, 8906, 8907" in specific notifications. The key issue was whether the goods/spares used were parts of warships/submarines. The ARA held that essential components like engines, gearbox, propeller, etc., are integral parts of a ship/vessel based on definitions of "part." Goods qualifying as parts of specific headings attract GST under the relevant notification. Items listed in Annexure 2A were deemed essential parts of a warship/submarine and subject to specific GST rates, while others in different annexures were not covered under the said notification.
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