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...
Services consisting of procurement, logistics and assured supply of quality medicines to government health facilities qualify as "pure services" intrinsically linked to health and sanitation functions entrusted to local government bodies. Rule 33 CGST (valuation of pure agent) cannot be read to define "pure services," and is irrelevant to that classification. Because the activities fall within functions of Panchayats and Municipalities concerning public health, such pure services supplied to the State attract nil-rate GST under Sl. No. 3 of Notification No. 12/2017 CT (Rate); the appellant is therefore entitled to the exemption.
Services consisting of procurement, logistics and assured supply of quality medicines to government health facilities qualify as "pure services" intrinsically linked to health and sanitation functions entrusted to local government bodies. Rule 33 CGST (valuation of pure agent) cannot be read to define "pure services," and is irrelevant to that classification. Because the activities fall within functions of Panchayats and Municipalities concerning public health, such pure services supplied to the State attract nil-rate GST under Sl. No. 3 of Notification No. 12/2017 CT (Rate); the appellant is therefore entitled to the exemption.
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