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 the applicant's activities relating to field-level data validation of Functional Household Tap Connections, orientation programmes for mission stakeholders, and GIS-based collection and visualization of components of Piped Water Supply Schemes are integrally connected to supply of safe drinking water under JJM. These services fall within functions under Serial No. 11 of the Eleventh Schedule to Art. 243G and Serial No. 5 of the Twelfth Schedule to Art. 243W. As the contracts involve only software development, data management and training, with no supply of goods, they constitute "pure services". Accordingly, they are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
AAR held that the applicant's activities relating to field-level data validation of Functional Household Tap Connections, orientation programmes for mission stakeholders, and GIS-based collection and visualization of components of Piped Water Supply Schemes are integrally connected to supply of safe drinking water under JJM. These services fall within functions under Serial No. 11 of the Eleventh Schedule to Art. 243G and Serial No. 5 of the Twelfth Schedule to Art. 243W. As the contracts involve only software development, data management and training, with no supply of goods, they constitute "pure services". Accordingly, they are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
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