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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Valuation of service tax - wharfage charges under Port Service - In the present case, there is no dispute that the gross amount charged by EBTL to ESTL is equivalent to 20% of notified rate of wharfage charges and there is no additional consideration therefore, the amount charged by EBTL to ESTL is the sole consideration therefore, the value determined in the present case is strictly in accordance with Section 67 of the Act. - the gross amount charged by EBTL to ESTL being sole consideration will alone be liable to service tax and no any other amount which is otherwise not existing. - AT
Valuation of service tax - wharfage charges under Port Service - In the present case, there is no dispute that the gross amount charged by EBTL to ESTL is equivalent to 20% of notified rate of wharfage charges and there is no additional consideration therefore, the amount charged by EBTL to ESTL is the sole consideration therefore, the value determined in the present case is strictly in accordance with Section 67 of the Act. - the gross amount charged by EBTL to ESTL being sole consideration will alone be liable to service tax and no any other amount which is otherwise not existing. - AT
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