Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Residential staff quarters built for Government departments and agencies were treated as intended for personal use, so the demand on those contracts remained dropped. Services for GETCO and other non-commercial Government works were also sustained as non-taxable, including transmission and distribution of electricity works covered by exemption principles. By contrast, construction services for APMC were held taxable for the pre-negative list period because APMC renting or allotting space is commercial in nature under Supreme Court precedent. The extended period was upheld due to non-registration, non-filing, non-payment and suppression, while recomputation had to allow the works contract composition scheme and cum-tax benefit, with penalty to follow the revised demand.
Residential staff quarters built for Government departments and agencies were treated as intended for personal use, so the demand on those contracts remained dropped. Services for GETCO and other non-commercial Government works were also sustained as non-taxable, including transmission and distribution of electricity works covered by exemption principles. By contrast, construction services for APMC were held taxable for the pre-negative list period because APMC renting or allotting space is commercial in nature under Supreme Court precedent. The extended period was upheld due to non-registration, non-filing, non-payment and suppression, while recomputation had to allow the works contract composition scheme and cum-tax benefit, with penalty to follow the revised demand.
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