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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Recovery of short paid service tax - Construction of Complex Service - adjustment of the excess service tax paid - Service Tax when introduced followed the receipt based accounting system for levy and collection of tax. The assessee was obliged to pay the taxes on the basis of the gross amounts received during the taxing period. - the entire issue is because of the change in the manner of accounting of the transaction for the purpose of computation of service tax liability from the accrual basis to the receipt basis. - The issue needs to be adjudged in the favour of appellant - AT
Recovery of short paid service tax - Construction of Complex Service - adjustment of the excess service tax paid - Service Tax when introduced followed the receipt based accounting system for levy and collection of tax. The assessee was obliged to pay the taxes on the basis of the gross amounts received during the taxing period. - the entire issue is because of the change in the manner of accounting of the transaction for the purpose of computation of service tax liability from the accrual basis to the receipt basis. - The issue needs to be adjudged in the favour of appellant - AT
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