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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Requirement of registration - Tamil Nadu Skill development Corporation(TNSDC) - The applicant is not an SSC approved by the NSDC - In the instant case the activities of TNSDC are ‘Supply’ as per Section 7(1) and are not excluded under Section 7(2). Further by the definition of business, the intent of ‘profit’ is not necessary for the activity. Also, only the ‘subsidy’ granted by the Government, stands excluded from ‘Consideration’. Therefore, the supply undertaken by the applicant is liable to GST and subject to the monetary Turnover of the applicant, the applicant is liable to obtain GST Registration - AAR
Requirement of registration - Tamil Nadu Skill development Corporation(TNSDC) - The applicant is not an SSC approved by the NSDC - In the instant case the activities of TNSDC are ‘Supply’ as per Section 7(1) and are not excluded under Section 7(2). Further by the definition of business, the intent of ‘profit’ is not necessary for the activity. Also, only the ‘subsidy’ granted by the Government, stands excluded from ‘Consideration’. Therefore, the supply undertaken by the applicant is liable to GST and subject to the monetary Turnover of the applicant, the applicant is liable to obtain GST Registration - AAR
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