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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Valuation of taxable services - installation and commissioning and works contract services - the adjudicating authority has not recorded any specific finding as to what amount is to be considered for the purpose of determination of the service tax liability, there are no hesitation, but in accepting the commercial documents submitted by the appellants to conclude that there is proper bifurcation of the amount towards supply of equipment and towards the services for installation and commissioning of the same at the site of the customer. - demand set aside - AT
Valuation of taxable services - installation and commissioning and works contract services - the adjudicating authority has not recorded any specific finding as to what amount is to be considered for the purpose of determination of the service tax liability, there are no hesitation, but in accepting the commercial documents submitted by the appellants to conclude that there is proper bifurcation of the amount towards supply of equipment and towards the services for installation and commissioning of the same at the site of the customer. - demand set aside - AT
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