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 denied the rectification application, holding that rectification under Section 102 is permissible only for errors apparent on the face of the record and that no such error existed. The applicant sought insertion of a provision characterising body-building activity performed on a chassis owned by an unregistered customer as supply of services under SI No. 26(iv) / heading 998881 read with Schedule II; the AAR found the requested text redundant because the substance of that contention had already been addressed in the advance ruling. Consequently, the rectification petition was rejected as untenable under Section 98(2) of the CGST/TNGST Act, 2017.
The AAR denied the rectification application, holding that rectification under Section 102 is permissible only for errors apparent on the face of the record and that no such error existed. The applicant sought insertion of a provision characterising body-building activity performed on a chassis owned by an unregistered customer as supply of services under SI No. 26(iv) / heading 998881 read with Schedule II; the AAR found the requested text redundant because the substance of that contention had already been addressed in the advance ruling. Consequently, the rectification petition was rejected as untenable under Section 98(2) of the CGST/TNGST Act, 2017.
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