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...
AAR held that third-party organization marketing exempted yoga courses cannot claim GST exemption on yoga course fees collected on behalf of yoga institutions. While Rule 33 CGST Rules 2017 permits exclusion of amounts collected by pure agents, applicant failed to provide documentary evidence establishing compliance with mandatory conditions including contractual arrangements authorizing expense incurrence, separate invoice indication, and strict cost pass-through without markup. Without demonstrating pure agent status within Rule 33 parameters, GST exemption on yoga course fee component was denied. Organization remains liable for GST on entire transaction value including collected fees despite underlying yoga courses being exempt.
AAR held that third-party organization marketing exempted yoga courses cannot claim GST exemption on yoga course fees collected on behalf of yoga institutions. While Rule 33 CGST Rules 2017 permits exclusion of amounts collected by pure agents, applicant failed to provide documentary evidence establishing compliance with mandatory conditions including contractual arrangements authorizing expense incurrence, separate invoice indication, and strict cost pass-through without markup. Without demonstrating pure agent status within Rule 33 parameters, GST exemption on yoga course fee component was denied. Organization remains liable for GST on entire transaction value including collected fees despite underlying yoga courses being exempt.
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