Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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AAR held that exemption under Sr. No. 557B of Notification No. 50/2017-Customs from IGST is available to the applicant on lease of equipment supplied from an FTWZ unit to DTA for use in manufacture of a rig. Although the applicant is not an SEZ unit, the goods are physically stored in an FTWZ, which is treated as an SEZ under the SEZ Act, 2005, and FTWZ-DTA transactions are permissible. Subject to compliance with Condition 102 (bond for retention, re-export/return, and payment on breach), the DTA unit is entitled to the exemption.
AAR held that exemption under Sr. No. 557B of Notification No. 50/2017-Customs from IGST is available to the applicant on lease of equipment supplied from an FTWZ unit to DTA for use in manufacture of a rig. Although the applicant is not an SEZ unit, the goods are physically stored in an FTWZ, which is treated as an SEZ under the SEZ Act, 2005, and FTWZ-DTA transactions are permissible. Subject to compliance with Condition 102 (bond for retention, re-export/return, and payment on breach), the DTA unit is entitled to the exemption.
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