Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The AAR held that the GST rate for the project is governed by the one-time option exercised by the original promoter at 12% with input tax credit. The applicant is bound by this project-specific election and cannot switch to a 5% rate without input tax credit. The ruling emphasizes that the tax treatment is project-based, not promoter-specific. Consequently, the applicant must discharge GST at 18% (9% CGST + 9% SGST) with input tax credit, applying a one-third deduction for land value. The option applies uniformly to existing and new buyers, preventing differential tax rates within the same project.
The AAR held that the GST rate for the project is governed by the one-time option exercised by the original promoter at 12% with input tax credit. The applicant is bound by this project-specific election and cannot switch to a 5% rate without input tax credit. The ruling emphasizes that the tax treatment is project-based, not promoter-specific. Consequently, the applicant must discharge GST at 18% (9% CGST + 9% SGST) with input tax credit, applying a one-third deduction for land value. The option applies uniformly to existing and new buyers, preventing differential tax rates within the same project.
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