Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Centage charges collected for project management consultancy, involving only supervision, coordination and administrative management without any transfer of property in goods or works contract, were held to constitute "pure services." As such services were supplied to Government/local authorities in relation to functions entrusted to Panchayats/Municipalities under Articles 243G/243W read with the Eleventh and Twelfth Schedules, they were held exempt under Entry 3 of Notification No. 12/2017-CTR, rendering the centage charges non-taxable under GST. Refund of GST already paid was held to be governed solely by Section 54, requiring filing within two years from the date of tax payment; the authority lacked jurisdiction to relax this limitation. - AAR
Centage charges collected for project management consultancy, involving only supervision, coordination and administrative management without any transfer of property in goods or works contract, were held to constitute "pure services." As such services were supplied to Government/local authorities in relation to functions entrusted to Panchayats/Municipalities under Articles 243G/243W read with the Eleventh and Twelfth Schedules, they were held exempt under Entry 3 of Notification No. 12/2017-CTR, rendering the centage charges non-taxable under GST. Refund of GST already paid was held to be governed solely by Section 54, requiring filing within two years from the date of tax payment; the authority lacked jurisdiction to relax this limitation. - AAR
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