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 supply does not constitute a "pure service" as defined under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, since the consideration received included both the procurement value of goods and service charges without segregation. The applicant failed to satisfy clause (d) of the relevant explanation, which requires distinct treatment of procurement costs separate from service charges to qualify as a pure agent. Consequently, the supply cannot be classified as a pure service, rendering the applicant ineligible for the exemption under Sl. No. 3 of the said notification. The ruling confirms that when goods and services are bundled without clear separation of values, the exemption for pure services does not apply.
The AAR held that the applicant's supply does not constitute a "pure service" as defined under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, since the consideration received included both the procurement value of goods and service charges without segregation. The applicant failed to satisfy clause (d) of the relevant explanation, which requires distinct treatment of procurement costs separate from service charges to qualify as a pure agent. Consequently, the supply cannot be classified as a pure service, rendering the applicant ineligible for the exemption under Sl. No. 3 of the said notification. The ruling confirms that when goods and services are bundled without clear separation of values, the exemption for pure services does not apply.
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