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 AAAR held that the respondent, M/s. Sikka Ports and Terminals Ltd., is not eligible for availing input tax credit (ITC) on input services for repairs and maintenance of Diving Support Vessels (DSVs) and Security Patrol Vessels (SPVs) as these vessels are not used for transportation of goods. Additionally, the respondent cannot claim ITC on hiring of SPVs u/s 17(5)(b) of the CGST Act, 2017, as the hiring service was not used for making an outward taxable supply of the same category of service or as an element of a taxable composite or mixed supply.
The AAAR held that the respondent, M/s. Sikka Ports and Terminals Ltd., is not eligible for availing input tax credit (ITC) on input services for repairs and maintenance of Diving Support Vessels (DSVs) and Security Patrol Vessels (SPVs) as these vessels are not used for transportation of goods. Additionally, the respondent cannot claim ITC on hiring of SPVs u/s 17(5)(b) of the CGST Act, 2017, as the hiring service was not used for making an outward taxable supply of the same category of service or as an element of a taxable composite or mixed supply.
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