Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Construction of residential villas under direct buyer agreements remains a taxable supply of services even where the actual building work is fully outsourced, because the promoter retains contractual responsibility and the outsourced work is only a mode of performance. The transaction is treated as a naturally bundled composite supply, with construction of the villa as the principal supply; the specific residential construction entry under Heading 9954(ia) applies over the general works contract entry. For valuation, the notified GST mechanism for construction involving land requires deduction of one-third of the total amount charged as deemed land value, and actual land pricing does not displace that statutory formula.
Construction of residential villas under direct buyer agreements remains a taxable supply of services even where the actual building work is fully outsourced, because the promoter retains contractual responsibility and the outsourced work is only a mode of performance. The transaction is treated as a naturally bundled composite supply, with construction of the villa as the principal supply; the specific residential construction entry under Heading 9954(ia) applies over the general works contract entry. For valuation, the notified GST mechanism for construction involving land requires deduction of one-third of the total amount charged as deemed land value, and actual land pricing does not displace that statutory formula.
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