SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
AAR held that the dry lease of a Bell 412 EP helicopter by the applicant to the lessee constitutes a taxable "transfer of right to use" goods, meeting the BSNL test: delivery of the aircraft with engines, avionics, manuals and records, provision of airworthy condition and licences, and effective control passing to the lessee. The supply is classifiable under HSN 9973 (leasing/rental services without operator) and falls within Sl. No. 17(iii) of Notification No. 11/2017-CT(R). As the helicopter is employed for commercial, non-personal use by a non-scheduled air transport operator, the transaction attracts GST at 5% as prescribed under the applicable notification.
AAR held that the dry lease of a Bell 412 EP helicopter by the applicant to the lessee constitutes a taxable "transfer of right to use" goods, meeting the BSNL test: delivery of the aircraft with engines, avionics, manuals and records, provision of airworthy condition and licences, and effective control passing to the lessee. The supply is classifiable under HSN 9973 (leasing/rental services without operator) and falls within Sl. No. 17(iii) of Notification No. 11/2017-CT(R). As the helicopter is employed for commercial, non-personal use by a non-scheduled air transport operator, the transaction attracts GST at 5% as prescribed under the applicable notification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
