Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
