Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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AAR held that, for supplies of goods, time of supply for a registered person not under composition is mandatorily determined under s.12(2)(a) CGST Act, as modified by Notif. 66/2017, i.e., on the earlier of the date of issue of invoice or the last date on which the invoice is required to be issued, and not on the date of receipt of advance. The applicant is not permitted to issue multiple tax invoices for a single supply of a boat against successive advances. For advances, only a receipt voucher under s.31(3)(d) r/w Rule 50 may be issued; a single tax invoice under Rule 46 must be issued at the time of supply, and the e-way bill must reflect the full value of the boat against this invoice. Credit notes cannot be used to nullify earlier advance invoices, as such invoices are not permissible in law.
AAR held that, for supplies of goods, time of supply for a registered person not under composition is mandatorily determined under s.12(2)(a) CGST Act, as modified by Notif. 66/2017, i.e., on the earlier of the date of issue of invoice or the last date on which the invoice is required to be issued, and not on the date of receipt of advance. The applicant is not permitted to issue multiple tax invoices for a single supply of a boat against successive advances. For advances, only a receipt voucher under s.31(3)(d) r/w Rule 50 may be issued; a single tax invoice under Rule 46 must be issued at the time of supply, and the e-way bill must reflect the full value of the boat against this invoice. Credit notes cannot be used to nullify earlier advance invoices, as such invoices are not permissible in law.
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