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...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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Fresh adjudication of a service-tax demand was required after relevant work contracts and agreements were placed on record and the Department accepted reconsideration on the entire material. The claimed exemption had not been examined on its merits. The demand order and consequential penalties were set aside, with remand for reconsideration of the available and any further relevant documents after giving the petitioner an opportunity of hearing.
Fresh adjudication of a service-tax demand was required after relevant work contracts and agreements were placed on record and the Department accepted reconsideration on the entire material. The claimed exemption had not been examined on its merits. The demand order and consequential penalties were set aside, with remand for reconsideration of the available and any further relevant documents after giving the petitioner an opportunity of hearing.
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