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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Nature of activity - service or not - petitioner joined hands with two other owners and sold about 19.07 acres of land, of which, 5.43 acres belongs to the petitioner - There is no merits in this writ petition. It is for the petitioner to convince the appellate authority to come to a conclusion that neither the petitioner has provided any taxable service within the meaning of Section 65 (B) (44) of the Finance Act, 1994 or that the service provided by the petitioner well within the negative list under Section 65 (D) of the Finance Act, 1994 or was exempted under the Mega Exemption notification issued by the Central Government under Section 93 of the Finance Act, 1994. - HC
Nature of activity - service or not - petitioner joined hands with two other owners and sold about 19.07 acres of land, of which, 5.43 acres belongs to the petitioner - There is no merits in this writ petition. It is for the petitioner to convince the appellate authority to come to a conclusion that neither the petitioner has provided any taxable service within the meaning of Section 65 (B) (44) of the Finance Act, 1994 or that the service provided by the petitioner well within the negative list under Section 65 (D) of the Finance Act, 1994 or was exempted under the Mega Exemption notification issued by the Central Government under Section 93 of the Finance Act, 1994. - HC
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