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 applicant purchases vouchers by paying consideration to the issuer and sells them to clients for consideration. The vouchers have value and ownership transferrable from issuer to applicant and then to ultimate beneficiary. No service element exists between issuer and applicant or applicant and purchaser. Vouchers qualify as movable property and goods. Actionable claims other than lottery, betting, and gambling are neither goods nor services supply under GST. The applicant is involved in trading vouchers for consideration in business, selling at profit. This transaction amounts to supply of goods u/s 7(1)(a) of CGST Act 2017, involving title transfer covered under "goods" as per Schedule II. The vouchers are taxable as per residual entry no. 453 of Third Schedule of N/N. 01/2017-Central Tax (Rate) at 9% CGST and 9% UPGST rate.
The applicant purchases vouchers by paying consideration to the issuer and sells them to clients for consideration. The vouchers have value and ownership transferrable from issuer to applicant and then to ultimate beneficiary. No service element exists between issuer and applicant or applicant and purchaser. Vouchers qualify as movable property and goods. Actionable claims other than lottery, betting, and gambling are neither goods nor services supply under GST. The applicant is involved in trading vouchers for consideration in business, selling at profit. This transaction amounts to supply of goods u/s 7(1)(a) of CGST Act 2017, involving title transfer covered under "goods" as per Schedule II. The vouchers are taxable as per residual entry no. 453 of Third Schedule of N/N. 01/2017-Central Tax (Rate) at 9% CGST and 9% UPGST rate.
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