Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Cleaning and on-board housekeeping services supplied to Indian Railways are described as exempt from service tax. Before 1 July 2012, cleaning railway stations and coaches was treated as outside taxable cleaning services because those locations and rolling stock were not commercial or industrial premises. From that date, cleaning, sanitation, conservancy, waste management, toilet disinfection and related housekeeping were treated as municipal functions provided to Government and covered by Entry 25 of Notification No. 25/2012-ST. The notes also state that extended limitation cannot rest on suppression where the Department already knew the same activities and facts, and that retention of collected service tax requires supporting evidence.
Cleaning and on-board housekeeping services supplied to Indian Railways are described as exempt from service tax. Before 1 July 2012, cleaning railway stations and coaches was treated as outside taxable cleaning services because those locations and rolling stock were not commercial or industrial premises. From that date, cleaning, sanitation, conservancy, waste management, toilet disinfection and related housekeeping were treated as municipal functions provided to Government and covered by Entry 25 of Notification No. 25/2012-ST. The notes also state that extended limitation cannot rest on suppression where the Department already knew the same activities and facts, and that retention of collected service tax requires supporting evidence.
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