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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Charitable activities or not - GST on the amounts received in the form of Donation / Grants from various entities including Central Government and State Government - the applicant does not satisfy the conditions mentioned at Sr.No. 1 of Notification No. 12/2017 dated 28-06-2017 which provides exemption from tax to Services supplied by an entity registered under Section 12AA of the Income-Tax Act, 1961 (43 of 1961) by way of charitable activities and hence the supply undertaken by the applicant is not exempt on this count - Since the activities undertaken by the applicant do not conform strictly to the definition of a ‘charitable activity, the applicant shall obtain registration under GST Act. - AAR
Charitable activities or not - GST on the amounts received in the form of Donation / Grants from various entities including Central Government and State Government - the applicant does not satisfy the conditions mentioned at Sr.No. 1 of Notification No. 12/2017 dated 28-06-2017 which provides exemption from tax to Services supplied by an entity registered under Section 12AA of the Income-Tax Act, 1961 (43 of 1961) by way of charitable activities and hence the supply undertaken by the applicant is not exempt on this count - Since the activities undertaken by the applicant do not conform strictly to the definition of a ‘charitable activity, the applicant shall obtain registration under GST Act. - AAR
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