Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The AAR determined that supply, design, installation, testing, and commissioning of grid-connected rooftop solar power plants constitute a composite works contract involving immovable property. The ruling established a bifurcated tax treatment: 12% IGST on 70% of the gross value (representing goods component) and 18% IGST on 30% of the gross value (representing services component). The decision hinged on the permanent nature of the solar installation, interpreting it as inseparably attached to the earth, thus qualifying as a works contract under GST regulations. The tax calculation is based on the total gross consideration charged by the supplier.
The AAR determined that supply, design, installation, testing, and commissioning of grid-connected rooftop solar power plants constitute a composite works contract involving immovable property. The ruling established a bifurcated tax treatment: 12% IGST on 70% of the gross value (representing goods component) and 18% IGST on 30% of the gross value (representing services component). The decision hinged on the permanent nature of the solar installation, interpreting it as inseparably attached to the earth, thus qualifying as a works contract under GST regulations. The tax calculation is based on the total gross consideration charged by the supplier.
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