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 ruling pertains to the exemption from GST on pure services provided by a Goods Transport Agency (GTA) to an unregistered foreign entity. The applicant, a GTA-cum-Packing & Moving Company, claimed exemption under relevant notifications. However, the ruling clarified that the exemption is exclusively for services by a GTA to an unregistered person, where a GTA is defined as one issuing consignment notes for road transport of goods. As the applicant did not issue consignment notes, it was held ineligible for the exemption. Additionally, the applicant provided a bundle of services like customs clearance, loading/unloading, port handling, etc., individually charged, further disqualifying it from the exemption meant for pure GTA services. Consequently, the exemption was deemed inapplicable to the applicant's case.
The ruling pertains to the exemption from GST on pure services provided by a Goods Transport Agency (GTA) to an unregistered foreign entity. The applicant, a GTA-cum-Packing & Moving Company, claimed exemption under relevant notifications. However, the ruling clarified that the exemption is exclusively for services by a GTA to an unregistered person, where a GTA is defined as one issuing consignment notes for road transport of goods. As the applicant did not issue consignment notes, it was held ineligible for the exemption. Additionally, the applicant provided a bundle of services like customs clearance, loading/unloading, port handling, etc., individually charged, further disqualifying it from the exemption meant for pure GTA services. Consequently, the exemption was deemed inapplicable to the applicant's case.
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