Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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AAR held that the applicant is not entitled to claim input tax credit of GST charged on lease rental for land allotted for construction of an industrial unit, as such credit is specifically barred by section 17(5)(d) of the CGST Act. The bar applies irrespective of timing (pre-construction or post-construction), to any vacant portion of the leased land reserved for the project, and extends to amounts attributable to reconstruction, renovation, addition, alteration or repairs, since "construction" encompasses those activities. The Authority rejected attempts to limit section 17(5)(d) by reference to nexus or to section 17(5)(c), noting both clauses operate independently.
AAR held that the applicant is not entitled to claim input tax credit of GST charged on lease rental for land allotted for construction of an industrial unit, as such credit is specifically barred by section 17(5)(d) of the CGST Act. The bar applies irrespective of timing (pre-construction or post-construction), to any vacant portion of the leased land reserved for the project, and extends to amounts attributable to reconstruction, renovation, addition, alteration or repairs, since "construction" encompasses those activities. The Authority rejected attempts to limit section 17(5)(d) by reference to nexus or to section 17(5)(c), noting both clauses operate independently.
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