Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The AAR held that marine engines (HSN 8408), their spares (HSN 8409), and marine gearboxes (HSN 8483) supplied as parts of fishing vessels classified under Customs Tariff Heading 8902 attract a concessional GST rate of 5% under Serial No. 252 of Schedule I, Notification No. 01/2017-Central Tax (Rate). Classification remains under Chapter 84, but concessional rate applies due to end-use in fishing vessels. Repair and maintenance services of these vessels constitute a composite supply, predominantly of services under Heading 998714, taxable at 5% as per Notification No. 02/2021. Marine fuels used for propulsion qualify for 5% GST under amended Notification No. 14/2019, but marine engine oil, classified as lubricants (HSN 27101972), does not qualify and is taxable at 18%. The ruling emphasizes strict adherence to classification and end-use documentation to avail concessional rates.
The AAR held that marine engines (HSN 8408), their spares (HSN 8409), and marine gearboxes (HSN 8483) supplied as parts of fishing vessels classified under Customs Tariff Heading 8902 attract a concessional GST rate of 5% under Serial No. 252 of Schedule I, Notification No. 01/2017-Central Tax (Rate). Classification remains under Chapter 84, but concessional rate applies due to end-use in fishing vessels. Repair and maintenance services of these vessels constitute a composite supply, predominantly of services under Heading 998714, taxable at 5% as per Notification No. 02/2021. Marine fuels used for propulsion qualify for 5% GST under amended Notification No. 14/2019, but marine engine oil, classified as lubricants (HSN 27101972), does not qualify and is taxable at 18%. The ruling emphasizes strict adherence to classification and end-use documentation to avail concessional rates.
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