Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Consultancy and project management services consisting of architectural and supervisory activities, without transfer of property in goods, qualify as pure services rather than a works contract; the recipient is a local authority and the services relate to municipal functions (fire services, public amenities including parking) under Article 243W, with staff quarters for fire personnel treated as integrally linked to fire services. Because all conditions of Sl. No. 3 of Notification No. 12/2017 Central Tax (Rate) are met, such supplies to the municipal authority are exempt from GST; ancillary questions on past tax collection/refund were not adjudicated.
Consultancy and project management services consisting of architectural and supervisory activities, without transfer of property in goods, qualify as pure services rather than a works contract; the recipient is a local authority and the services relate to municipal functions (fire services, public amenities including parking) under Article 243W, with staff quarters for fire personnel treated as integrally linked to fire services. Because all conditions of Sl. No. 3 of Notification No. 12/2017 Central Tax (Rate) are met, such supplies to the municipal authority are exempt from GST; ancillary questions on past tax collection/refund were not adjudicated.
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