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...
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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