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 - Clearing services as such Grass, Bush, Jungle cutting at Area-III of ONGC Ank. And regular maintenance as tender documents - There is absolutely no doubt that the said activity amounted to provision of the cleaning services as defined in Section 65 (24b) of Finance Act, 1994 and there could not have been any bonafide doubt to in that regard - there are no merit in the argument that the appellant, harboured a bonafide view. - AT
Levy of service tax - Clearing services as such Grass, Bush, Jungle cutting at Area-III of ONGC Ank. And regular maintenance as tender documents - There is absolutely no doubt that the said activity amounted to provision of the cleaning services as defined in Section 65 (24b) of Finance Act, 1994 and there could not have been any bonafide doubt to in that regard - there are no merit in the argument that the appellant, harboured a bonafide view. - AT
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