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...
The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
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