Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh determination as per Tribunal and HC precedents. Distribution segment - TNMM as MAM directed, ALP computation remanded. Books not rejected. Not DAPE of Google Ireland, payments not royalty/FTS. Section 10A deduction - recomputation as per SC and HC precedents. IT segment comparables remanded for fresh determination as per APA. No attribution of Google Ireland's profits. Section 10A eligibility for ITeS segment remanded for AO verification based on documents.
TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh determination as per Tribunal and HC precedents. Distribution segment - TNMM as MAM directed, ALP computation remanded. Books not rejected. Not DAPE of Google Ireland, payments not royalty/FTS. Section 10A deduction - recomputation as per SC and HC precedents. IT segment comparables remanded for fresh determination as per APA. No attribution of Google Ireland's profits. Section 10A eligibility for ITeS segment remanded for AO verification based on documents.
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