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TAKKO HOLDING GMBH
(Authority for Advance Ruling, Tamilnadu)

Hon'ble Judges:

MANASA GANGOTRI KATA
S.VIJAYAKUMAR
Pet. Counsel
Na
Res. Counsel
Na

Petitioner / Applicant

TAKKO HOLDING GMBH

Respondent NA
Court

AAR (Authority for Advance Ruling)

State

Tamilnadu

Date Sep 27, 2018
Order No.

14/AAR/2018

Citation

2018(9) TAXREPLY 303

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ORDER

All the administrative expenses are met by the German office. (I.e. as per RBI instruction in their approval; the entire expenses of the office in India is met exclusively out of the funds received from abroad through normal banking channels). 2.3 They have stated that under GST supply includes all forms of suppiy made for a consideration by a person in course or furtherance of business. For activity of Liaison office, no consideration is being received. The Liaison office is maintained by inward remittances from German office to meet expenses. Hence, activities are not a supply. It will not come under S1. No. 2 of Schedule I as services without consideration from related persons or distinct persons as German Office and Liaison Office are not related person as there is only one legal entity and no relationship can be established. They are not a distinct person under Section 25 as distinct persons have establishments in more than one state or Union Territory. As per RBI terms and....

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