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...
Waste dump remediation and legacy waste processing services, involving excavation, segregation, scientific disposal and conversion into RDF, compost, grit and inert fractions, were classified under SAC 9994 for sewage, waste collection, treatment, disposal and other environmental protection services, and held taxable at 18%. The supply to Goa Waste Management Corporation was nevertheless treated as pure services, because no goods were involved and the activity related to solid waste management and bio-remediation, a municipal function under Article 243W; exemption under Sl. No. 3 of Notification No. 12/2017-CT was therefore available. A separate query on the recipient's status was declined as outside the scope of advance ruling jurisdiction under Section 97(2).
Waste dump remediation and legacy waste processing services, involving excavation, segregation, scientific disposal and conversion into RDF, compost, grit and inert fractions, were classified under SAC 9994 for sewage, waste collection, treatment, disposal and other environmental protection services, and held taxable at 18%. The supply to Goa Waste Management Corporation was nevertheless treated as pure services, because no goods were involved and the activity related to solid waste management and bio-remediation, a municipal function under Article 243W; exemption under Sl. No. 3 of Notification No. 12/2017-CT was therefore available. A separate query on the recipient's status was declined as outside the scope of advance ruling jurisdiction under Section 97(2).
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