Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
AAR ruled ITC unavailable for goods and services used in increasing height of Tailing Dam for mining waste disposal. The dam, classified as immovable property and civil structure stretching several kilometers on natural foundation, does not qualify as "plant and machinery" under CGST Act Section 17(5)(c) and (d). The dam, serving merely as storage for mining waste, does not directly contribute to mineral extraction or processing. Being constructed on taxpayer's own account for business operations setting, it falls within ITC restriction. The structure's passive storage function, without impact on mineral quality or quantity, prevents it from being considered essential to core business activities, thus disqualifying ITC claims.
AAR ruled ITC unavailable for goods and services used in increasing height of Tailing Dam for mining waste disposal. The dam, classified as immovable property and civil structure stretching several kilometers on natural foundation, does not qualify as "plant and machinery" under CGST Act Section 17(5)(c) and (d). The dam, serving merely as storage for mining waste, does not directly contribute to mineral extraction or processing. Being constructed on taxpayer's own account for business operations setting, it falls within ITC restriction. The structure's passive storage function, without impact on mineral quality or quantity, prevents it from being considered essential to core business activities, thus disqualifying ITC claims.
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