Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The works rendered by the applicant involving application of polymer protective coating for bridges, as part of construction or routine maintenance/renovation, falls under the definition of "works contract" u/s 2(119) of the CGST Act, 2017, and will be treated as supply of service under Service Code 995473. The composite supply of such works contract for construction, erection, commissioning, installation, completion, fitting out, repair, maintenance, renovation, or alteration of a bridge for road transportation for use by the general public is taxable at 12% under Notification 11/2017-Central Tax (Rate), as amended. The status or category of the recipient is immaterial for determining the tax rate. The applicable tax rate may vary based on the time of supply, being 18% (9% CGST and 9% SGST) from 01.07.2017 to 21.08.2017, 12% (6% CGST and 6% SGST) from 22.08.2017 to 17.07.2022, and 18% (9% CGST and 9% SGST) from 18.07.2022 onwards. The eligibility for exemption under Notification 12/2017-Central Tax (Rate) is deemed irrelevant based on the ruling.
The works rendered by the applicant involving application of polymer protective coating for bridges, as part of construction or routine maintenance/renovation, falls under the definition of "works contract" u/s 2(119) of the CGST Act, 2017, and will be treated as supply of service under Service Code 995473. The composite supply of such works contract for construction, erection, commissioning, installation, completion, fitting out, repair, maintenance, renovation, or alteration of a bridge for road transportation for use by the general public is taxable at 12% under Notification 11/2017-Central Tax (Rate), as amended. The status or category of the recipient is immaterial for determining the tax rate. The applicable tax rate may vary based on the time of supply, being 18% (9% CGST and 9% SGST) from 01.07.2017 to 21.08.2017, 12% (6% CGST and 6% SGST) from 22.08.2017 to 17.07.2022, and 18% (9% CGST and 9% SGST) from 18.07.2022 onwards. The eligibility for exemption under Notification 12/2017-Central Tax (Rate) is deemed irrelevant based on the ruling.
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