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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
In real estate anti-profiteering analysis, the governing approach is to test project-level GST savings by comparing credit availed to purchase value in the pre-GST and post-GST periods. Applying that method, the Tribunal accepted the DGAP's use of purchase-value ratios, excluded reversed credit and units outside the relevant pre-occupancy sale pool, and held that no additional benefit had accrued to the developer. It also accepted that ledger adjustments could evidence passing on of input tax credit, and that the EPC contractor was not the supplier to homebuyers. The objections to methodology, verification, and alleged inconsistency were rejected, and no contravention of Section 171 was found.
In real estate anti-profiteering analysis, the governing approach is to test project-level GST savings by comparing credit availed to purchase value in the pre-GST and post-GST periods. Applying that method, the Tribunal accepted the DGAP's use of purchase-value ratios, excluded reversed credit and units outside the relevant pre-occupancy sale pool, and held that no additional benefit had accrued to the developer. It also accepted that ledger adjustments could evidence passing on of input tax credit, and that the EPC contractor was not the supplier to homebuyers. The objections to methodology, verification, and alleged inconsistency were rejected, and no contravention of Section 171 was found.
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