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 - Joint venture - expenditure incurred by the appellant, in respect of its employees and assets which were deployed for undertaking joint operations at the blocks, where it was acting as the Operator - Infact, the appellant had as a co-venturer, in furtherance of the venture as its capital contribution to the venture, deployed manpower and assets for its own benefit and in the furtherance of the venture. This cannot, by any stretch of imagination, be regarded as a service being provided, so as to attract levy of service tax. - AT
Levy of Service Tax - Joint venture - expenditure incurred by the appellant, in respect of its employees and assets which were deployed for undertaking joint operations at the blocks, where it was acting as the Operator - Infact, the appellant had as a co-venturer, in furtherance of the venture as its capital contribution to the venture, deployed manpower and assets for its own benefit and in the furtherance of the venture. This cannot, by any stretch of imagination, be regarded as a service being provided, so as to attract levy of service tax. - AT
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