Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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AAR held that the applicant's activity of providing self-drive passenger vehicles (without driver) on rent is classifiable under Heading 9973 as "leasing or rental services without operator," specifically under residual Service Code 997329 concerning other goods. It does not qualify as "transfer of the right to use goods" under Entry 17(iii) of Notif. No. 11/2017-CT (Rate) as the lessee does not obtain exclusive possession and effective control; the owner retains significant control through GPS tracking, contractual restrictions, and right to intervene. Consequently, Entry 17(iii) is inapplicable. AAR ruled that the service is covered by Entry 17(viia) (leasing or renting of goods) and not by residual Entry 17(viii). The applicable GST rate is that leviable on the supply of like goods.
AAR held that the applicant's activity of providing self-drive passenger vehicles (without driver) on rent is classifiable under Heading 9973 as "leasing or rental services without operator," specifically under residual Service Code 997329 concerning other goods. It does not qualify as "transfer of the right to use goods" under Entry 17(iii) of Notif. No. 11/2017-CT (Rate) as the lessee does not obtain exclusive possession and effective control; the owner retains significant control through GPS tracking, contractual restrictions, and right to intervene. Consequently, Entry 17(iii) is inapplicable. AAR ruled that the service is covered by Entry 17(viia) (leasing or renting of goods) and not by residual Entry 17(viii). The applicable GST rate is that leviable on the supply of like goods.
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