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 service tax - advertising agency service or not - activity of wide format printing - assessee has no role at all in the conceptualization or in the making or creation of design. In fact, the respondent has no authority at all to even make any changes in the advertisement content provided by the customers and the respondent merely prints that on the PVC material procured from the market. This activity would not fall within the scope of the activity contemplated under section 65(3) of the Finance Act. - AT
Levy of service tax - advertising agency service or not - activity of wide format printing - assessee has no role at all in the conceptualization or in the making or creation of design. In fact, the respondent has no authority at all to even make any changes in the advertisement content provided by the customers and the respondent merely prints that on the PVC material procured from the market. This activity would not fall within the scope of the activity contemplated under section 65(3) of the Finance Act. - AT
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