Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Semen sex sorting services are classified as support services to animal husbandry and exempt from GST because the specialised laboratory processing of semen supplied by semen stations qualifies as job work and an intermediate production process in relation to rearing of animals; consequently the activity falls within Heading 9986 and benefits from the nil rate in Entry No. 24 to Notification No. 11/2017 CT(R). The prefatory rule favouring a specific description over a residual one means semen sorting cannot be classified under the general 'not elsewhere classified' entry (SAC 998399) when Heading 9986 specifically applies.
Semen sex sorting services are classified as support services to animal husbandry and exempt from GST because the specialised laboratory processing of semen supplied by semen stations qualifies as job work and an intermediate production process in relation to rearing of animals; consequently the activity falls within Heading 9986 and benefits from the nil rate in Entry No. 24 to Notification No. 11/2017 CT(R). The prefatory rule favouring a specific description over a residual one means semen sorting cannot be classified under the general 'not elsewhere classified' entry (SAC 998399) when Heading 9986 specifically applies.
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