Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The AAR held that the service of regasification of LNG owned by a third party, provided through an intermediary under contractual arrangements, constitutes job work within the meaning of section 2(68) of the CGST Act, 2017. The applicant acts as a job worker for the owner of the goods, without holding ownership. The service is classifiable under serial no. 26(id) of notification No. 11/2017-CT (R) and is subject to GST at 12%. The ruling confirms that the activity is a back-to-back job work arrangement, and the applicable tax treatment aligns with the prescribed classification for such services.
The AAR held that the service of regasification of LNG owned by a third party, provided through an intermediary under contractual arrangements, constitutes job work within the meaning of section 2(68) of the CGST Act, 2017. The applicant acts as a job worker for the owner of the goods, without holding ownership. The service is classifiable under serial no. 26(id) of notification No. 11/2017-CT (R) and is subject to GST at 12%. The ruling confirms that the activity is a back-to-back job work arrangement, and the applicable tax treatment aligns with the prescribed classification for such services.
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