Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
AAR held that the Applicant is not a "Promoter" and therefore does not fall within Notification No. 7/2019-CT(Rate); the goods received (M-sand, P-sand, blue metal, boulders, hollow bricks) from unregistered suppliers are neither notified under section 9(3) nor does the Applicant's activity fall within the scope of section 9(4). Consequently, the Applicant is not liable to discharge tax under the reverse charge mechanism on purchases of those goods from unregistered persons.
AAR held that the Applicant is not a "Promoter" and therefore does not fall within Notification No. 7/2019-CT(Rate); the goods received (M-sand, P-sand, blue metal, boulders, hollow bricks) from unregistered suppliers are neither notified under section 9(3) nor does the Applicant's activity fall within the scope of section 9(4). Consequently, the Applicant is not liable to discharge tax under the reverse charge mechanism on purchases of those goods from unregistered persons.
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