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 upheld that charges recovered by the applicant from consumers for deposit work (material and erection charges, pro-rata charges, supervision charges, proportionate line charges, registration fees) constitute incidental and ancillary activities to the principal supply of transmission of electricity. Relying on dictionary definitions and prior SC authority recognizing services as incidental when subordinate or appertaining to a primary activity, the AAR found these deposit works necessary for efficient intra-state transmission and thus integrally connected to the applicant's statutory transmission function. Consequentially, such charges qualify for exemption under Entry No. 25A of Notification No.12/2017 as amended by the later notification.
The AAR upheld that charges recovered by the applicant from consumers for deposit work (material and erection charges, pro-rata charges, supervision charges, proportionate line charges, registration fees) constitute incidental and ancillary activities to the principal supply of transmission of electricity. Relying on dictionary definitions and prior SC authority recognizing services as incidental when subordinate or appertaining to a primary activity, the AAR found these deposit works necessary for efficient intra-state transmission and thus integrally connected to the applicant's statutory transmission function. Consequentially, such charges qualify for exemption under Entry No. 25A of Notification No.12/2017 as amended by the later notification.
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