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 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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