Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The AAR ruled that fish processing services performed by the applicant on raw fish owned by registered persons constitute job work under Section 143 of the CGST Act. These services are properly classified under Chapter heading 998812 (manufacturing services on physical inputs owned by others). Following Notification No. 31/2017-CT(Rate) dated October 13, 2017, which amended Notification No. 11/2017-CT(Rate), such services attract a GST rate of 5% (2.5% CGST + 2.5% SGST). Prior to this amendment, the same activity was taxable at 18%. The 5% rate applies only when the applicant processes fish owned by registered persons while adhering to all statutory procedures applicable to both principal and job worker.
The AAR ruled that fish processing services performed by the applicant on raw fish owned by registered persons constitute job work under Section 143 of the CGST Act. These services are properly classified under Chapter heading 998812 (manufacturing services on physical inputs owned by others). Following Notification No. 31/2017-CT(Rate) dated October 13, 2017, which amended Notification No. 11/2017-CT(Rate), such services attract a GST rate of 5% (2.5% CGST + 2.5% SGST). Prior to this amendment, the same activity was taxable at 18%. The 5% rate applies only when the applicant processes fish owned by registered persons while adhering to all statutory procedures applicable to both principal and job worker.
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