Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The AAR ruled that the Tie-in pipeline, which transfers re-gasified LNG from FSRU to the National Grid, does not qualify as "plant and machinery" under Section 17 of the CGST Act. Despite using various technical systems and devices, the pipeline remains a structure laid outside factory premises. Consequently, the applicant is precluded from claiming Input Tax Credit (ITC) for GST paid on goods and services used in constructing the pipeline, as per Section 17(5)(c) and 17(5)(d) of the CGST Act, 2017, as amended by the Finance Act 2025.
The AAR ruled that the Tie-in pipeline, which transfers re-gasified LNG from FSRU to the National Grid, does not qualify as "plant and machinery" under Section 17 of the CGST Act. Despite using various technical systems and devices, the pipeline remains a structure laid outside factory premises. Consequently, the applicant is precluded from claiming Input Tax Credit (ITC) for GST paid on goods and services used in constructing the pipeline, as per Section 17(5)(c) and 17(5)(d) of the CGST Act, 2017, as amended by the Finance Act 2025.
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