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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4824 
Join Channel 
