Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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AAR held that the product constitutes a mixed supply under s.8(b) of the CGST Act, 2017 and must be classified by reference to the constituent supply attracting the highest rate of tax; where more than two supplies are combined, the rate and HSN of the component with the highest applicable tax governs classification. In the instant case all constituent items attract the same GST rate (5%); having regard to composition and predominance of chana dal, the AAR concluded the composite pack is taxable at 5% and is classifiable under the HSN corresponding to chana dal as the predominant constituent.
AAR held that the product constitutes a mixed supply under s.8(b) of the CGST Act, 2017 and must be classified by reference to the constituent supply attracting the highest rate of tax; where more than two supplies are combined, the rate and HSN of the component with the highest applicable tax governs classification. In the instant case all constituent items attract the same GST rate (5%); having regard to composition and predominance of chana dal, the AAR concluded the composite pack is taxable at 5% and is classifiable under the HSN corresponding to chana dal as the predominant constituent.
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