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    <title>2023 (6) TMI 828 - APPELLATE AUTHORITY FOR ADVANCE RULING, MAHARASHTRA</title>
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    <description>Rule 33 permits exclusion from the value of supply only where the supplier acts as a pure agent, the recipient authorises the third-party payment, the amount is separately indicated in the invoice, and the payment is incidental to the supplier&#039;s own supply. On the stated facts, the stipend and allied expenses were closely linked to the NEEM training arrangement, the facilitator bore the contractual responsibility for deployment and payment, and the receipts formed part of the consideration for the service rather than a pass-through reimbursement. The matter was also treated as capable of decision on merits despite objections based on the record. Consequently, the pure-agent exclusion was unavailable and the amounts remained taxable.</description>
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      <description>Rule 33 permits exclusion from the value of supply only where the supplier acts as a pure agent, the recipient authorises the third-party payment, the amount is separately indicated in the invoice, and the payment is incidental to the supplier&#039;s own supply. On the stated facts, the stipend and allied expenses were closely linked to the NEEM training arrangement, the facilitator bore the contractual responsibility for deployment and payment, and the receipts formed part of the consideration for the service rather than a pass-through reimbursement. The matter was also treated as capable of decision on merits despite objections based on the record. Consequently, the pure-agent exclusion was unavailable and the amounts remained taxable.</description>
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