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Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The applicant's services do not constitute a transfer of the right to use goods, as substantial control remains with the contractor and is not handed over to the user. The contracts in question are leasing or rental services without an operator, falling under Sl. No. 17 (viii) of Notification No. 11/2017 Central Tax (Rate) dated 28-06-2017. Such services attract GST at the rate of 18%, as per the Advance Ruling Authority's decision.
The applicant's services do not constitute a transfer of the right to use goods, as substantial control remains with the contractor and is not handed over to the user. The contracts in question are leasing or rental services without an operator, falling under Sl. No. 17 (viii) of Notification No. 11/2017 Central Tax (Rate) dated 28-06-2017. Such services attract GST at the rate of 18%, as per the Advance Ruling Authority's decision.
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