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 services of collecting household data through a mobile app for Functional Household Tap Connection (FHTC) under the Jal Jeevan Mission constitute pure services in relation to functions entrusted to Panchayats and Municipalities under Art. 243G and 243W of the Constitution. The activities, involving software development and data collection without any supply of goods, are integrally connected to supply of safe drinking water and water distribution networks in West Bengal. Accordingly, the services are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
AAR held that the applicant's services of collecting household data through a mobile app for Functional Household Tap Connection (FHTC) under the Jal Jeevan Mission constitute pure services in relation to functions entrusted to Panchayats and Municipalities under Art. 243G and 243W of the Constitution. The activities, involving software development and data collection without any supply of goods, are integrally connected to supply of safe drinking water and water distribution networks in West Bengal. Accordingly, the services are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
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