Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
AAR held that services rendered by the applicant to the recipient-society are not exempt under Entry 72 of Notif. No. 12/2017-CT (Rate) because the recipient, though under administrative control and funding of the State, is a separate legal entity registered as a society and cannot be treated as the Central/State Government or a Government Department. It may at best qualify as a Governmental Authority/Entity, but the training, skill development and capacity-building services supplied do not fall within the limited categories exempted under Entry 3B of Notif. No. 13/2023-CT (Rate). Consequently, the supplies are taxable. As a corollary, AAR held the applicant is entitled to full ITC on GST charged by subcontractors for such services, subject to satisfaction of statutory conditions under the CGST Act and Rules.
AAR held that services rendered by the applicant to the recipient-society are not exempt under Entry 72 of Notif. No. 12/2017-CT (Rate) because the recipient, though under administrative control and funding of the State, is a separate legal entity registered as a society and cannot be treated as the Central/State Government or a Government Department. It may at best qualify as a Governmental Authority/Entity, but the training, skill development and capacity-building services supplied do not fall within the limited categories exempted under Entry 3B of Notif. No. 13/2023-CT (Rate). Consequently, the supplies are taxable. As a corollary, AAR held the applicant is entitled to full ITC on GST charged by subcontractors for such services, subject to satisfaction of statutory conditions under the CGST Act and Rules.
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