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...
Comparable-service valuation under service-tax rules requires comparison between service recipients who stand on the same footing. Flats and a commercial unit allotted without monetary consideration to existing occupants under a redevelopment arrangement could not be valued by reference to sale prices of flats sold to new buyers, because the two recipient groups were not comparable. Since service tax had already been discharged on flats sold to new buyers, the demand based on an assumed value for allotments to existing occupants was unsustainable. The service-tax demand, consequential interest and penalty were set aside.
Comparable-service valuation under service-tax rules requires comparison between service recipients who stand on the same footing. Flats and a commercial unit allotted without monetary consideration to existing occupants under a redevelopment arrangement could not be valued by reference to sale prices of flats sold to new buyers, because the two recipient groups were not comparable. Since service tax had already been discharged on flats sold to new buyers, the demand based on an assumed value for allotments to existing occupants was unsustainable. The service-tax demand, consequential interest and penalty were set aside.
Note: It is a system-generated summary and is for quick reference only.