Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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