Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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