Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The AAR ruled that the applicant cannot avail Input Tax Credit (ITC) on inputs and services used for constructing a concrete tower to support VCV lines for manufacturing EHV cables. Applying the Supreme Court's functionality test from Safari Retreats, the AAR determined that while a building may qualify as "plant" under Section 17(5)(d) of CGST Act, ITC is unavailable when construction is for the recipient's own use. The AAR found the applicant failed to prove the construction was not on their own account, breaking the ITC chain. The authority dismissed the applicant's reliance on various judgments as irrelevant, noting they primarily pertained to Income Tax matters rather than GST provisions.
The AAR ruled that the applicant cannot avail Input Tax Credit (ITC) on inputs and services used for constructing a concrete tower to support VCV lines for manufacturing EHV cables. Applying the Supreme Court's functionality test from Safari Retreats, the AAR determined that while a building may qualify as "plant" under Section 17(5)(d) of CGST Act, ITC is unavailable when construction is for the recipient's own use. The AAR found the applicant failed to prove the construction was not on their own account, breaking the ITC chain. The authority dismissed the applicant's reliance on various judgments as irrelevant, noting they primarily pertained to Income Tax matters rather than GST provisions.
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