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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Classification of services - a co-loader / courier agency - Whatever the evidence placed on record indicate that the appellant has rendered services to other courier agencies and was not involved in the in-transit movement of courier parcels to be called a “co-loader”. According to the appellant, courier parcels were collected from various customers in its jurisdiction which were reportedly sent abroad through M/s. United Business Xpress India Pvt. Ltd., New Delhi. It is not possible, in the absence of any documentary evidence i.e., any agreement / contract / terms of payment for rendering these services, to determine that its services are that of a co-loader. - AT
Classification of services - a co-loader / courier agency - Whatever the evidence placed on record indicate that the appellant has rendered services to other courier agencies and was not involved in the in-transit movement of courier parcels to be called a “co-loader”. According to the appellant, courier parcels were collected from various customers in its jurisdiction which were reportedly sent abroad through M/s. United Business Xpress India Pvt. Ltd., New Delhi. It is not possible, in the absence of any documentary evidence i.e., any agreement / contract / terms of payment for rendering these services, to determine that its services are that of a co-loader. - AT
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