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 ruled on GST applicability for electricity transmission utility services. The key findings are: shifting/raising transmission towers at third-party request constitutes a taxable supply under service category "agreeing to do an act" (HSN 999792). The services are not transmission-related but infrastructure modification services. The supply is chargeable at 18% GST under Section 7 of CGST Act, 2017. Time of supply follows Section 13 of CGST Act. The value of supply is determined under Section 15 of CGST Act. Input tax credit availability depends on whether the construction relates to plant and machinery or immovable property. The ruling clarifies that infrastructure modification services for dedicated consumers are taxable commercial transactions.
The AAR ruled on GST applicability for electricity transmission utility services. The key findings are: shifting/raising transmission towers at third-party request constitutes a taxable supply under service category "agreeing to do an act" (HSN 999792). The services are not transmission-related but infrastructure modification services. The supply is chargeable at 18% GST under Section 7 of CGST Act, 2017. Time of supply follows Section 13 of CGST Act. The value of supply is determined under Section 15 of CGST Act. Input tax credit availability depends on whether the construction relates to plant and machinery or immovable property. The ruling clarifies that infrastructure modification services for dedicated consumers are taxable commercial transactions.
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