Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Where a taxpayer precasts concrete offsite and brings personnel and machinery to a construction site, the site exhibits sufficient permanence and use of human and technical resources to constitute a fixed establishment; consequence: registration is required in the state of the construction site. Transportation and use of precast materials at that site by the same registered person, even without separate consideration or a distinct contracting party, falls within the scope of supply (Schedule I and Section 7) because the supplier is treated as a distinct person; consequence: such movements amount to supply. Procedural queries outside Section 97(2) are rejected as inadmissible.
Where a taxpayer precasts concrete offsite and brings personnel and machinery to a construction site, the site exhibits sufficient permanence and use of human and technical resources to constitute a fixed establishment; consequence: registration is required in the state of the construction site. Transportation and use of precast materials at that site by the same registered person, even without separate consideration or a distinct contracting party, falls within the scope of supply (Schedule I and Section 7) because the supplier is treated as a distinct person; consequence: such movements amount to supply. Procedural queries outside Section 97(2) are rejected as inadmissible.
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