Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
The AAR ruled that no GST is payable on goods (gas) lost during transit as no supply occurred, since the loss happened before delivery to the customer and prior to the place and time of supply being established. However, the applicant must reverse Input Tax Credit (ITC) on inputs used in manufacturing the goods subsequently lost in transit. The authority determined that such inputs fail the "proper end use" condition under Section 16(1) of CGST Act, as they were not ultimately used in furtherance of business through a taxable outward supply. The ITC reversal is required under Section 17(5)(h) read with Section 16, as the goods were lost/destroyed during transit.
The AAR ruled that no GST is payable on goods (gas) lost during transit as no supply occurred, since the loss happened before delivery to the customer and prior to the place and time of supply being established. However, the applicant must reverse Input Tax Credit (ITC) on inputs used in manufacturing the goods subsequently lost in transit. The authority determined that such inputs fail the "proper end use" condition under Section 16(1) of CGST Act, as they were not ultimately used in furtherance of business through a taxable outward supply. The ITC reversal is required under Section 17(5)(h) read with Section 16, as the goods were lost/destroyed during transit.
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