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 fly ash bricks are classifiable under HSN 6815 99 10 and, with effect from 18.07.2022, attract GST at 12% (CGST) irrespective of fly ash percentage; the prior fly-ash-content condition has been omitted and the applicant is not entitled to a concessional 6% rate. The supply is taxable under the normal taxation mechanism (not reverse charge). Fly ash bricks are not exempt merely by virtue of recycled/sustainable content and no special concessional treatment applies for supplies to Government/PSUs. A manufacturer may avail ITC on inputs and input services if otherwise eligible when charging 12%; the Composition Scheme is unavailable to manufacturers of fly ash bricks. The GST treatment of raw fly ash was held outside the AAR's remit.
The AAR held that fly ash bricks are classifiable under HSN 6815 99 10 and, with effect from 18.07.2022, attract GST at 12% (CGST) irrespective of fly ash percentage; the prior fly-ash-content condition has been omitted and the applicant is not entitled to a concessional 6% rate. The supply is taxable under the normal taxation mechanism (not reverse charge). Fly ash bricks are not exempt merely by virtue of recycled/sustainable content and no special concessional treatment applies for supplies to Government/PSUs. A manufacturer may avail ITC on inputs and input services if otherwise eligible when charging 12%; the Composition Scheme is unavailable to manufacturers of fly ash bricks. The GST treatment of raw fly ash was held outside the AAR's remit.
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