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 - Renting of Immovable Property Services - vacant land solely used for mining purposes - support services or not - Pertinently after the deletion of the words “support services” in Section 66D (a). The demand of service tax is made under reverse charge mechanism for the period after 01.04.2016 after the substitution of the word “any service” in clause (iv) of Section 66D (a) whereas the demand in these appeals is on the allegation that ‘renting of immovable property’ is a ‘support service’ The words ‘support services’ having been omitted w.e.f. 01.04.2016, the circular is not applicable for the period after 01.04.2016 - AT
Levy of service tax - Renting of Immovable Property Services - vacant land solely used for mining purposes - support services or not - Pertinently after the deletion of the words “support services” in Section 66D (a). The demand of service tax is made under reverse charge mechanism for the period after 01.04.2016 after the substitution of the word “any service” in clause (iv) of Section 66D (a) whereas the demand in these appeals is on the allegation that ‘renting of immovable property’ is a ‘support service’ The words ‘support services’ having been omitted w.e.f. 01.04.2016, the circular is not applicable for the period after 01.04.2016 - AT
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