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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Levy of service tax - Commercial Coaching or Training Services - conducting training courses and providing certificates to the students without the approval of UGC or AICTE - Right from beginning till 30.06.2017 the activity of the appellant in providing educational /vocational training to their students, is as per the pre defined curriculum in collaboration with the respective University, is exempt throughout,as they have provided education and training followed by issue of certificate of degree/ diploma which is recognised by law for the time being in force. Further, we find that on completion of the courses conducted by the appellants, the students/ trainees have either received employment and/or are competent to be self employed. - Demand set aside - AT
Levy of service tax - Commercial Coaching or Training Services - conducting training courses and providing certificates to the students without the approval of UGC or AICTE - Right from beginning till 30.06.2017 the activity of the appellant in providing educational /vocational training to their students, is as per the pre defined curriculum in collaboration with the respective University, is exempt throughout,as they have provided education and training followed by issue of certificate of degree/ diploma which is recognised by law for the time being in force. Further, we find that on completion of the courses conducted by the appellants, the students/ trainees have either received employment and/or are competent to be self employed. - Demand set aside - AT
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