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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CENVAT Credit - input service - amount paid to the broker / property consultant for purchasing the immovable property to be used for providing output service of renting of immovable property - The amount in question is the amount given to the person who rendered the services of getting purchased the immovable property through which the output service of renting of immovable property could not have been provided. The brokerage/ consultancy services received for setting up of said immovable property is accordingly held to be an eligible inputs service.- AT
CENVAT Credit - input service - amount paid to the broker / property consultant for purchasing the immovable property to be used for providing output service of renting of immovable property - The amount in question is the amount given to the person who rendered the services of getting purchased the immovable property through which the output service of renting of immovable property could not have been provided. The brokerage/ consultancy services received for setting up of said immovable property is accordingly held to be an eligible inputs service.- AT
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