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 application - Input Tax Credit - common input services utilized for both taxable as well as exempted supply - the Appellant has sought a ruling whether the credit on such commonly used services can be availed. This question undoubtedly involves examining the admissibility of credit on the common input services which are used by them in their Mysuru unit in the course or for the furtherance of business - The lower Authority was incorrect in not giving a ruling on this question. - AAAR
Scope of advance ruling application - Input Tax Credit - common input services utilized for both taxable as well as exempted supply - the Appellant has sought a ruling whether the credit on such commonly used services can be availed. This question undoubtedly involves examining the admissibility of credit on the common input services which are used by them in their Mysuru unit in the course or for the furtherance of business - The lower Authority was incorrect in not giving a ruling on this question. - AAAR
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