Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
An AAR held that hiring electric buses with drivers, where the recipient controlled routes, frequency and schedules, is rental of road vehicles with operator under SAC 996601. It further held that the word "fuel" in Entry 10(i) of Notification No. 11/2017-CT(R) carries its ordinary meaning as a combustible material and does not include electricity. Because electricity was outside the scope of fuel, the concessional entry did not apply and the service fell under the residual Entry 10(iii), attracting GST at 18%.
An AAR held that hiring electric buses with drivers, where the recipient controlled routes, frequency and schedules, is rental of road vehicles with operator under SAC 996601. It further held that the word "fuel" in Entry 10(i) of Notification No. 11/2017-CT(R) carries its ordinary meaning as a combustible material and does not include electricity. Because electricity was outside the scope of fuel, the concessional entry did not apply and the service fell under the residual Entry 10(iii), attracting GST at 18%.
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