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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The phase “in respect of roads” contained in clause (25b) of Section 65 ibid has a wider connotation and bears the widest possible scope and may be taken to mean “for the provision of”. Thus, the service tax demand on Toll Plaza and Lanes will not be sustainable in this case. - AT
The phase “in respect of roads” contained in clause (25b) of Section 65 ibid has a wider connotation and bears the widest possible scope and may be taken to mean “for the provision of”. Thus, the service tax demand on Toll Plaza and Lanes will not be sustainable in this case. - AT
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