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 particulate matter permits are tradable goods, not securities, and are classifiable under HSN Heading 4907 (residuary code 4970 00 90). Applying ejusdem generis, the Authority rejected treating PM-permits as akin to bonds, stocks or debentures. The permits confer transferable economic benefits, have market value, are auctioned on the designated trading platform and may be sold for profit; accordingly proceeds constitute business income and sales are in the course or furtherance of business. Restrictions on transferability or expiry do not alter their character as goods. The applicable GST rate on trading of PM-permits is 12%.
The AAR held that particulate matter permits are tradable goods, not securities, and are classifiable under HSN Heading 4907 (residuary code 4970 00 90). Applying ejusdem generis, the Authority rejected treating PM-permits as akin to bonds, stocks or debentures. The permits confer transferable economic benefits, have market value, are auctioned on the designated trading platform and may be sold for profit; accordingly proceeds constitute business income and sales are in the course or furtherance of business. Restrictions on transferability or expiry do not alter their character as goods. The applicable GST rate on trading of PM-permits is 12%.
Note: It is a system-generated summary and is for quick reference only.
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