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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Maintainability of Reference to Third to member - Difference of opinion - Classification of services - internet telecommunication service or not - The decisions, on which reliance has been placed by learned authorized representative, would not come to the aid of the Department as it has been found as a fact in the present case that the learned Members have set out the point on which they differ and it is not that the entire matter has been referred to the Third Member. - AT
Maintainability of Reference to Third to member - Difference of opinion - Classification of services - internet telecommunication service or not - The decisions, on which reliance has been placed by learned authorized representative, would not come to the aid of the Department as it has been found as a fact in the present case that the learned Members have set out the point on which they differ and it is not that the entire matter has been referred to the Third Member. - AT
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