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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Scope of advance ruling - proposed activity - Classification of goods - rate of GST - Fly Ash Blocks - It is seen that the applicant has no infrastructural facilities for the proposed manufacture, has not received any orders for supply of the proposed product to be manufactured. Further from the report from the Jurisdiction authority it is evident that the applicant has not substantiated any infrastructure (in terms of raw materials/machinery/demand, etc) based on which such a supply can be undertaken by them. In this scenario, it is held that the application made by them is pre-mature and does not fall under the ambit of the proposed transaction i.e., proposed supply of goods or services. - AAR
Scope of advance ruling - proposed activity - Classification of goods - rate of GST - Fly Ash Blocks - It is seen that the applicant has no infrastructural facilities for the proposed manufacture, has not received any orders for supply of the proposed product to be manufactured. Further from the report from the Jurisdiction authority it is evident that the applicant has not substantiated any infrastructure (in terms of raw materials/machinery/demand, etc) based on which such a supply can be undertaken by them. In this scenario, it is held that the application made by them is pre-mature and does not fall under the ambit of the proposed transaction i.e., proposed supply of goods or services. - AAR
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