Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Assignment of long-term (95-year) leasehold rights that extinguishes the transferor's rights and vests benefits in an assignee constitutes a transfer of benefits arising out of immovable property, not a supply of services under the GST supply framework; accordingly, classification of such assignment as 'other miscellaneous services' taxable at 18% was legally unsustainable and a show cause notice premised on that classification was quashed. The decision emphasises absence of nexus with the transferor's business and the character of the long term lease as determinative of tax treatment.
Assignment of long-term (95-year) leasehold rights that extinguishes the transferor's rights and vests benefits in an assignee constitutes a transfer of benefits arising out of immovable property, not a supply of services under the GST supply framework; accordingly, classification of such assignment as 'other miscellaneous services' taxable at 18% was legally unsustainable and a show cause notice premised on that classification was quashed. The decision emphasises absence of nexus with the transferor's business and the character of the long term lease as determinative of tax treatment.
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