Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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