Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Under Hybrid Annuity Mode (HAM) for National Highway Projects, concessionaire constructs new road and provides Operation & Maintenance over 15-17 years with payment staggered over years. HAM contract is single contract for construction and O&M, cannot be split into separate contracts. Payment is continuous supply of services u/s 2(33). Time of supply is date of invoice or receipt of payment, whichever is earlier, if invoice issued within prescribed period u/s 31(5). If invoice not issued within prescribed period, time of supply is date of provision of service or receipt of payment, whichever is earlier, with date of provision deemed as due date of payment. Tax liability arises at time of invoice or receipt of payment, whichever is earlier. Interest component in annuity/instalment is includible in taxable value u/s 15(2)(d).
Under Hybrid Annuity Mode (HAM) for National Highway Projects, concessionaire constructs new road and provides Operation & Maintenance over 15-17 years with payment staggered over years. HAM contract is single contract for construction and O&M, cannot be split into separate contracts. Payment is continuous supply of services u/s 2(33). Time of supply is date of invoice or receipt of payment, whichever is earlier, if invoice issued within prescribed period u/s 31(5). If invoice not issued within prescribed period, time of supply is date of provision of service or receipt of payment, whichever is earlier, with date of provision deemed as due date of payment. Tax liability arises at time of invoice or receipt of payment, whichever is earlier. Interest component in annuity/instalment is includible in taxable value u/s 15(2)(d).
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