Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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NSDC-approved training partners conducting NSQF-aligned digital marketing courses were treated as supplying training services exempt under Entry 69 of Notification No. 12/2017-CT(R), because the services fell within the skill development framework covered by the notification. After Notification No. 08/2024-CT(R), NCVET-accredited training bodies and NSDC-approved training partners were treated as separate categories, so the applicant could not claim the NCVET route merely because the course was NSQF-aligned. The exemption for the intervening period was therefore unavailable on the notification wording, but the tax position for that period was directed to be regularised on an as is where is basis, with no tax recoverable if unpaid and no refund if already paid.
NSDC-approved training partners conducting NSQF-aligned digital marketing courses were treated as supplying training services exempt under Entry 69 of Notification No. 12/2017-CT(R), because the services fell within the skill development framework covered by the notification. After Notification No. 08/2024-CT(R), NCVET-accredited training bodies and NSDC-approved training partners were treated as separate categories, so the applicant could not claim the NCVET route merely because the course was NSQF-aligned. The exemption for the intervening period was therefore unavailable on the notification wording, but the tax position for that period was directed to be regularised on an as is where is basis, with no tax recoverable if unpaid and no refund if already paid.
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