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...
AAR held that the Applicant's supply of pre-packaged and labelled rice (≤25 kg) for export is taxable under the IGST scheme at 5% if the Applicant opts for that route, provided the packages satisfy the notification's "pre-packaged & labelled" definition. Supplies to an exporter on a bill-to/ship-to basis and supplies to an exporter's factory are likewise taxable at 5%, but the concessional rate of 0.1% (0.05%+0.05%) under the relevant notifications is available for such supplies subject to their terms and conditions. The erstwhile restriction precluding IGST payment where concessional benefits were availed has been removed, so procuring at 0.1% does not bar exporting under IGST 5%.
AAR held that the Applicant's supply of pre-packaged and labelled rice (≤25 kg) for export is taxable under the IGST scheme at 5% if the Applicant opts for that route, provided the packages satisfy the notification's "pre-packaged & labelled" definition. Supplies to an exporter on a bill-to/ship-to basis and supplies to an exporter's factory are likewise taxable at 5%, but the concessional rate of 0.1% (0.05%+0.05%) under the relevant notifications is available for such supplies subject to their terms and conditions. The erstwhile restriction precluding IGST payment where concessional benefits were availed has been removed, so procuring at 0.1% does not bar exporting under IGST 5%.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
