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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Commercial or industrial construction service - services rendered to Government bodies and other entities - benefit exemption has been denied for the reason that the services have been rendered in the factory area - Scope of 'Factory' - the premises where the post-production processes take place towards making the produce commercially viable would qualify as a factory - the oil fields of ONGC, where only extraction of crude oil takes places, would not qualify as a ‘factory’. - The Commissioner committed an illegality in denying the benefit of the Notification dated 20.06.2012 at Serial No. 13(d) to the appellant for ETPs constructed for ONGC and the STPs constructed for NBCC - AT
Commercial or industrial construction service - services rendered to Government bodies and other entities - benefit exemption has been denied for the reason that the services have been rendered in the factory area - Scope of 'Factory' - the premises where the post-production processes take place towards making the produce commercially viable would qualify as a factory - the oil fields of ONGC, where only extraction of crude oil takes places, would not qualify as a ‘factory’. - The Commissioner committed an illegality in denying the benefit of the Notification dated 20.06.2012 at Serial No. 13(d) to the appellant for ETPs constructed for ONGC and the STPs constructed for NBCC - AT
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