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...
The AAR held that the applicant's dredging and de-silting services performed using Cutter Suction Dredger in specified river channels for the Government of West Bengal constitute a pure service without any supply of goods. The activity involves excavation and removal of silt without any construction or creation of dumping grounds, thereby excluding it from works contract or composite supply classifications. Consequently, the service satisfies all conditions under Entry No. 3 of Notification No. 12/2017-Central Tax (Rate). The Authority ruled that the supply of dredging and removal of dredged materials falls within the scope of this entry, rendering the applicable GST rate as NIL.
The AAR held that the applicant's dredging and de-silting services performed using Cutter Suction Dredger in specified river channels for the Government of West Bengal constitute a pure service without any supply of goods. The activity involves excavation and removal of silt without any construction or creation of dumping grounds, thereby excluding it from works contract or composite supply classifications. Consequently, the service satisfies all conditions under Entry No. 3 of Notification No. 12/2017-Central Tax (Rate). The Authority ruled that the supply of dredging and removal of dredged materials falls within the scope of this entry, rendering the applicable GST rate as NIL.
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