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's transaction constitutes a composite "works contract" under s.2(119) CGST, permitting ITC only on the structural steel/plant-and-machinery component as delineated in the contract Cost Abstract/Bill of Quantities, and not on civil or sheeting components. Cranes and HVAC were characterised as plant and machinery, supporting the secondary steel's eligibility. Concerning advances, the AAR ruled that time-of-supply principles in s.13(2) render receipt of advance as deemed receipt, and therefore ITC on supplier invoices for advance payments may be availed subject to the temporal limitation in s.16(4) - i.e., before 30 November following the FY or on filing the annual return, whichever is earlier.
The AAR held that the applicant's transaction constitutes a composite "works contract" under s.2(119) CGST, permitting ITC only on the structural steel/plant-and-machinery component as delineated in the contract Cost Abstract/Bill of Quantities, and not on civil or sheeting components. Cranes and HVAC were characterised as plant and machinery, supporting the secondary steel's eligibility. Concerning advances, the AAR ruled that time-of-supply principles in s.13(2) render receipt of advance as deemed receipt, and therefore ITC on supplier invoices for advance payments may be availed subject to the temporal limitation in s.16(4) - i.e., before 30 November following the FY or on filing the annual return, whichever is earlier.
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