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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's services related to a naval vessel do not qualify as "Maintenance, repair or overhaul services" (MRO services) under Entry 25(ib) of Notification No. 11/2017 Central Tax (Rate) dated 28.06.2017 as amended by Notification No. 02/2021-Central Tax (rate) dated 02.06.2021. The services provided by the applicant, while related to a naval vessel, do not primarily constitute maintenance, repair, or overhaul in the conventional sense. Instead, they appear to be in the nature of upgradation or renovation works, involving supply and installation of goods. There is no specific maintenance agreement between the applicant and the Naval Dockyard, and the scope of work primarily involves up gradation and installation activities rather than repair or maintenance of existing equipment. The tender work rendered by the applicant does not fall under the scope of the concessional rate of tax provided in the amended notification.
The applicant's services related to a naval vessel do not qualify as "Maintenance, repair or overhaul services" (MRO services) under Entry 25(ib) of Notification No. 11/2017 Central Tax (Rate) dated 28.06.2017 as amended by Notification No. 02/2021-Central Tax (rate) dated 02.06.2021. The services provided by the applicant, while related to a naval vessel, do not primarily constitute maintenance, repair, or overhaul in the conventional sense. Instead, they appear to be in the nature of upgradation or renovation works, involving supply and installation of goods. There is no specific maintenance agreement between the applicant and the Naval Dockyard, and the scope of work primarily involves up gradation and installation activities rather than repair or maintenance of existing equipment. The tender work rendered by the applicant does not fall under the scope of the concessional rate of tax provided in the amended notification.
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