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...
AAR ruled on GST exemption for manpower services provided by the applicant to Webel Technology Limited (WTL) for a government project. While the services qualify as "pure services" under N/N. 12/2017-Central Tax (Rate), they do not meet exemption criteria since they are provided to WTL, not directly to Public Health Engineering Department (PHED) or any government entity. Despite WTL's contract with PHED for the Jal Jeevan Mission project, the applicant's services to WTL as a subcontractor do not qualify for exemption under serial number 3 of the notification. The services remain taxable under GST as they fail to satisfy the direct government service provision requirement.
AAR ruled on GST exemption for manpower services provided by the applicant to Webel Technology Limited (WTL) for a government project. While the services qualify as "pure services" under N/N. 12/2017-Central Tax (Rate), they do not meet exemption criteria since they are provided to WTL, not directly to Public Health Engineering Department (PHED) or any government entity. Despite WTL's contract with PHED for the Jal Jeevan Mission project, the applicant's services to WTL as a subcontractor do not qualify for exemption under serial number 3 of the notification. The services remain taxable under GST as they fail to satisfy the direct government service provision requirement.
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