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 GST - Valuation - reimbursement amount received by the Applicant from Trainer - Stipend and other expenses incurred - Both the Agreements attached by the applicant as 'Specimen Copies” in respect of the subject application do not provide a clear picture of the actual facts in respect of the present matter and therefore, the questions raised cannot be answered, due to incomplete and inconclusive documentation submitted by the applicant in respect of the subject application. - AAR
Levy of GST - Valuation - reimbursement amount received by the Applicant from Trainer - Stipend and other expenses incurred - Both the Agreements attached by the applicant as 'Specimen Copies” in respect of the subject application do not provide a clear picture of the actual facts in respect of the present matter and therefore, the questions raised cannot be answered, due to incomplete and inconclusive documentation submitted by the applicant in respect of the subject application. - AAR
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