SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
AAAR held that transportation services provided by appellant to school students and staff do not qualify for GST exemption under Serial No.66 of Notification 12/2017-Central Tax (Rate). The contractual arrangements demonstrated that appellant directly supplied transportation services to students/staff with fees collected from parents, while educational institutions neither provided nor received services in the transaction. The exemption notification requires services to be provided by or to educational institutions, which was not established. AAAR emphasized strict interpretation of exemption notifications with burden of proof on claimant. The ruling distinguished previous AAR decisions as non-binding and factually dissimilar, concluding exemption unavailable under present circumstances.
AAAR held that transportation services provided by appellant to school students and staff do not qualify for GST exemption under Serial No.66 of Notification 12/2017-Central Tax (Rate). The contractual arrangements demonstrated that appellant directly supplied transportation services to students/staff with fees collected from parents, while educational institutions neither provided nor received services in the transaction. The exemption notification requires services to be provided by or to educational institutions, which was not established. AAAR emphasized strict interpretation of exemption notifications with burden of proof on claimant. The ruling distinguished previous AAR decisions as non-binding and factually dissimilar, concluding exemption unavailable under present circumstances.
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TaxTMI 
TaxTMI 
of 4894 
