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Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
The note concludes that services of carrying segregated municipal waste for a municipal corporation constitute a pure service and fall within activities entrusted to municipalities under Article 243W; therefore they meet the three conditions for exemption under Serial No. 3 of Notification No.12/2017: (i) absence of transfer of property in goods or a works contract/composite supply, (ii) recipient is a local authority constituted under Articles 243P/243Q, and (iii) service relates to a Twelfth Schedule municipal function; consequently the service is tax exempt under that entry.
The note concludes that services of carrying segregated municipal waste for a municipal corporation constitute a pure service and fall within activities entrusted to municipalities under Article 243W; therefore they meet the three conditions for exemption under Serial No. 3 of Notification No.12/2017: (i) absence of transfer of property in goods or a works contract/composite supply, (ii) recipient is a local authority constituted under Articles 243P/243Q, and (iii) service relates to a Twelfth Schedule municipal function; consequently the service is tax exempt under that entry.
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