Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
AAR held that transfer of assets and liabilities from the transferor to the transferee constitutes a "service by way of transfer of a going concern as a whole or an independent part thereof" and is therefore an exempt supply under Sl. No. 2 of N/N 12/2017-CT(R). It further ruled that the work orders relating to digital asset management, GIS/WebGIS-based monitoring and stakeholder orientation for the State PHE Directorate are "pure services" to a Government department in relation to functions under JJM, eligible for exemption under Sl. No. 3 of N/N 12/2017-CT(R). Post-transfer invoices in continuation of such work orders retain the same taxability.
AAR held that transfer of assets and liabilities from the transferor to the transferee constitutes a "service by way of transfer of a going concern as a whole or an independent part thereof" and is therefore an exempt supply under Sl. No. 2 of N/N 12/2017-CT(R). It further ruled that the work orders relating to digital asset management, GIS/WebGIS-based monitoring and stakeholder orientation for the State PHE Directorate are "pure services" to a Government department in relation to functions under JJM, eligible for exemption under Sl. No. 3 of N/N 12/2017-CT(R). Post-transfer invoices in continuation of such work orders retain the same taxability.
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