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 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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