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 HC held that the assignment/sale/transfer of leasehold rights by the lessee to a third party for a lump-sum consideration is a transfer of "immovable property" and not a supply of service under the GST Act. The leasehold rights encompass incorporeal ownership rights over the land and building, constituting "immovable property". Consequently, such transactions are not subject to GST levy u/s 9(1) of the GST Act.
The HC held that the assignment/sale/transfer of leasehold rights by the lessee to a third party for a lump-sum consideration is a transfer of "immovable property" and not a supply of service under the GST Act. The leasehold rights encompass incorporeal ownership rights over the land and building, constituting "immovable property". Consequently, such transactions are not subject to GST levy u/s 9(1) of the GST Act.
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