Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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