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...
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...
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If prior to 16.05.2008, the service was correctly classifiable under franchise service and broader category was brought into the statute subsequently it does not mean that for the earlier period it could not have been classified under franchise service - stay granted partly - AT
If prior to 16.05.2008, the service was correctly classifiable under franchise service and broader category was brought into the statute subsequently it does not mean that for the earlier period it could not have been classified under franchise service - stay granted partly - AT
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