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...
The turnkey contract entered by the applicant with PGVCL is a works contract as defined u/s 2(119), involving a composite supply for installation, testing, and commissioning of 11 KV medium voltage covered conductor (MVCC) with accessories. The contract is not divisible, despite constituting two interconnected and interdependent parts. GST is payable on the advance received by the applicant for the turnkey contract, as per Section 12(2)(a) of the CGST Act, 2017. The benefit of Notification No. 66/2017-CT is not applicable to this turnkey contract, which is treated as a supply of service under Schedule II.
The turnkey contract entered by the applicant with PGVCL is a works contract as defined u/s 2(119), involving a composite supply for installation, testing, and commissioning of 11 KV medium voltage covered conductor (MVCC) with accessories. The contract is not divisible, despite constituting two interconnected and interdependent parts. GST is payable on the advance received by the applicant for the turnkey contract, as per Section 12(2)(a) of the CGST Act, 2017. The benefit of Notification No. 66/2017-CT is not applicable to this turnkey contract, which is treated as a supply of service under Schedule II.
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