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...
Classification of supply - Composite supply or Mixed Supply - The ‘a la carte’ services provided by the appellant, relating to employee relocation is neither a composite supply nor a mixed supply - the observations made by the Lower Authority in the impugned order to the effect that the service provided by the appellant is covered under the definition of “intermediary’ is expunged as being beyond the mandate of the Authority in the instant case. - AAAR
Classification of supply - Composite supply or Mixed Supply - The ‘a la carte’ services provided by the appellant, relating to employee relocation is neither a composite supply nor a mixed supply - the observations made by the Lower Authority in the impugned order to the effect that the service provided by the appellant is covered under the definition of “intermediary’ is expunged as being beyond the mandate of the Authority in the instant case. - AAAR
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