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 - reimbursement of electricity expenses, on actual basis, by the lessee to lessor - forming part of taxable value or not - In the instant case, the applicant had not acted as "pure agent" and invoice/bill/memo/document issued in relation to collect Electricity charges or incidental charges, maintenance charges, are in relation to composite supply of principal service of renting of immovable property as any incidental charges or expenses in respect of supply of service shall form part of value of taxable supply. Since the principal supply provided by the applicant (here Lessor) is of Renting & Leasing of Immovable Property (sac codes- 997212), it will attract GST @ of 18% of the taxable value of supply. - AAR
Valuation - reimbursement of electricity expenses, on actual basis, by the lessee to lessor - forming part of taxable value or not - In the instant case, the applicant had not acted as "pure agent" and invoice/bill/memo/document issued in relation to collect Electricity charges or incidental charges, maintenance charges, are in relation to composite supply of principal service of renting of immovable property as any incidental charges or expenses in respect of supply of service shall form part of value of taxable supply. Since the principal supply provided by the applicant (here Lessor) is of Renting & Leasing of Immovable Property (sac codes- 997212), it will attract GST @ of 18% of the taxable value of supply. - AAR
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