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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
IT software related consulting services - Export of services or not - services provided by the applicant to the foreign client through the Principal - ITC claim - payment of fees received by him in INR from the Principal - the said activity satisfies the conditions of Section 7(1){a) and is a supply under GST. As per Para 5 of Schedule II read with Section 7(1A), this supply is a supply of services.
IT software related consulting services - Export of services or not - services provided by the applicant to the foreign client through the Principal - ITC claim - payment of fees received by him in INR from the Principal - the said activity satisfies the conditions of Section 7(1){a) and is a supply under GST. As per Para 5 of Schedule II read with Section 7(1A), this supply is a supply of services.
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