Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions.
GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions.
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