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...
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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