Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The AAR held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
The AAR held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
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