Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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's share of fees received from skill training partners and fees collected from its own training institutes are liable to GST. The receipts do not qualify for exemption under Entry 69 or Entry 66 of Notif. No. 12/2017-CT(R), as the outsourced training partners are not shown to be NSDC/SSC approved, the courses are not NSQF/NCVET or statute-recognized, and the applicant is not an "educational institution" within para 2(y). Exemption under Sl. No. 4 is also denied as the services are not municipal functions under Art. 243W. On ITC, AAR declined a specific ruling for lack of factual detail but clarified that ITC cannot be denied merely because inputs are funded from a Government grant, subject to s.16 CGST Act conditions.
AAR held that the applicant's share of fees received from skill training partners and fees collected from its own training institutes are liable to GST. The receipts do not qualify for exemption under Entry 69 or Entry 66 of Notif. No. 12/2017-CT(R), as the outsourced training partners are not shown to be NSDC/SSC approved, the courses are not NSQF/NCVET or statute-recognized, and the applicant is not an "educational institution" within para 2(y). Exemption under Sl. No. 4 is also denied as the services are not municipal functions under Art. 243W. On ITC, AAR declined a specific ruling for lack of factual detail but clarified that ITC cannot be denied merely because inputs are funded from a Government grant, subject to s.16 CGST Act conditions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
