Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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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...
Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.
Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
