Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
The AAR ruled on classification of fitted assets supply services on hire basis. The authority determined that the applicant's services constitute leasing/rental services rather than goods leasing, as permanently installed machinery loses its movable property nature under GST. The services involve restricted supply up to tap off points without responsibility for input power quality. Distinguishing from cloud computing scenarios and referencing relevant precedents, the AAR classified the supply under serial no 17(viii) of Notification No. 11/2017-Central Tax (Rate). Being a mixed supply, the services attract GST at 18% rate as leasing/rental services, applying the highest applicable tax rate principle for mixed supplies.
The AAR ruled on classification of fitted assets supply services on hire basis. The authority determined that the applicant's services constitute leasing/rental services rather than goods leasing, as permanently installed machinery loses its movable property nature under GST. The services involve restricted supply up to tap off points without responsibility for input power quality. Distinguishing from cloud computing scenarios and referencing relevant precedents, the AAR classified the supply under serial no 17(viii) of Notification No. 11/2017-Central Tax (Rate). Being a mixed supply, the services attract GST at 18% rate as leasing/rental services, applying the highest applicable tax rate principle for mixed supplies.
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