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...
AAAR dismissed the appeal and upheld denial of exemption under entry 3 of Notification No. 12/2017, holding that the appellant's lease of building property to a government department for use as college hostels constitutes a pure supply of immovable property and is not made "in relation to" the statutory functions of panchayats or similar authorities. The authority determined that the phrase "in relation to" must be construed in its legal sense-concerning or pertaining to the statutory function-and the appellant's services were not sufficiently connected to those functions. Accordingly, the claimed exemption was rejected and the appeal was dismissed.
AAAR dismissed the appeal and upheld denial of exemption under entry 3 of Notification No. 12/2017, holding that the appellant's lease of building property to a government department for use as college hostels constitutes a pure supply of immovable property and is not made "in relation to" the statutory functions of panchayats or similar authorities. The authority determined that the phrase "in relation to" must be construed in its legal sense-concerning or pertaining to the statutory function-and the appellant's services were not sufficiently connected to those functions. Accordingly, the claimed exemption was rejected and the appeal was dismissed.
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