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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Computation of Service tax liability - Works Contract - the order of Court below calculating the service tax liability on 100% of the turn-over under works contract service is illegal and irresponsible in view of the mandate of law - The appellant are directed to calculate the service tax payable under the Rules and file a calculation sheet before the assessing officer. If any amount is still payable by them they shall pay the same. It is further held that under such circumstances no interest is payable - AT
Computation of Service tax liability - Works Contract - the order of Court below calculating the service tax liability on 100% of the turn-over under works contract service is illegal and irresponsible in view of the mandate of law - The appellant are directed to calculate the service tax payable under the Rules and file a calculation sheet before the assessing officer. If any amount is still payable by them they shall pay the same. It is further held that under such circumstances no interest is payable - AT
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