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 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.
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