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...
AAR determined that leasing 19 onion mandis to a contractor for daily fee collection constitutes a municipal function under Article 243W of the Constitution. The activity is exempt from GST as it falls within the scope of local authority's public functions. The transaction between the municipality and contractor is considered an inseparable public service activity, not a commercial supply of goods or services. The notification No. 14/2017-CT(Rate) applies, rendering the entire transaction outside the taxable domain. The key consideration was the functional nexus with constitutional municipal responsibilities, rather than the administrative mechanism of service delivery.
AAR determined that leasing 19 onion mandis to a contractor for daily fee collection constitutes a municipal function under Article 243W of the Constitution. The activity is exempt from GST as it falls within the scope of local authority's public functions. The transaction between the municipality and contractor is considered an inseparable public service activity, not a commercial supply of goods or services. The notification No. 14/2017-CT(Rate) applies, rendering the entire transaction outside the taxable domain. The key consideration was the functional nexus with constitutional municipal responsibilities, rather than the administrative mechanism of service delivery.
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