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 AAR determined that transportation services provided to students and staff could not be considered as services to the educational institution since the applicant received payment directly from students rather than the school, as evidenced by the Profit and Loss Account showing only "Bus Fees Receipt" from students with no financial transactions with the school. Consequently, these services are classified as "Transport of passenger by any motor vehicle" under SAC 9964, attracting 5% GST without ITC per Notification No. 11/2017 as amended. The exemption under Serial No. 66 of Notification No. 12/2017-Central Tax (Rate) is inapplicable as it requires services be provided to an educational institution, not directly to students.
The AAR determined that transportation services provided to students and staff could not be considered as services to the educational institution since the applicant received payment directly from students rather than the school, as evidenced by the Profit and Loss Account showing only "Bus Fees Receipt" from students with no financial transactions with the school. Consequently, these services are classified as "Transport of passenger by any motor vehicle" under SAC 9964, attracting 5% GST without ITC per Notification No. 11/2017 as amended. The exemption under Serial No. 66 of Notification No. 12/2017-Central Tax (Rate) is inapplicable as it requires services be provided to an educational institution, not directly to students.
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