Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
ITC of GST paid on services for surrendering leasehold rights not eligible when construction activity not undertaken on leasehold land. SC in Safari Retreats laid down functionality test - if building qualifies as plant, ITC available for renting/leasing, else not available if for recipient's own use. Appellant did not construct on leasehold land acquired from GACL despite stating 99.85% utilization for plant/machinery. GST paid on surrendering leasehold rights ineligible for ITC. Appeal dismissed by AAAR.
ITC of GST paid on services for surrendering leasehold rights not eligible when construction activity not undertaken on leasehold land. SC in Safari Retreats laid down functionality test - if building qualifies as plant, ITC available for renting/leasing, else not available if for recipient's own use. Appellant did not construct on leasehold land acquired from GACL despite stating 99.85% utilization for plant/machinery. GST paid on surrendering leasehold rights ineligible for ITC. Appeal dismissed by AAAR.
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