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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In the wake of the fact that even the Government acknowledged the existence of confusion/ambiguity with regard to the coverage of management, maintenance and repair of software under the Management, Maintenance or Repair Service to such a degree as to warrant addition of an explanation to clarify the issue and also in view of the aforesaid judicial precedents, it is amply clear that the extended period cannot be invoked - AT
In the wake of the fact that even the Government acknowledged the existence of confusion/ambiguity with regard to the coverage of management, maintenance and repair of software under the Management, Maintenance or Repair Service to such a degree as to warrant addition of an explanation to clarify the issue and also in view of the aforesaid judicial precedents, it is amply clear that the extended period cannot be invoked - AT
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