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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Local Authority or not - GST on procurement of security services - The appellant is neither a department nor establishment of the Central/State Government, nor a local authority as we have already held above nor persons or category of persons notified under notification No. 50/2018-CT - the appellant cannot deduct tax & hence is not required to be registered as deductor under GST. As far as 'Governmental agencies' are concerned, it is found that this has been dealt with in para 21.2 of the impugned order in detail. The Appellant has not produced anything to interfere with the findings of the GAAR. - AAAR
Local Authority or not - GST on procurement of security services - The appellant is neither a department nor establishment of the Central/State Government, nor a local authority as we have already held above nor persons or category of persons notified under notification No. 50/2018-CT - the appellant cannot deduct tax & hence is not required to be registered as deductor under GST. As far as 'Governmental agencies' are concerned, it is found that this has been dealt with in para 21.2 of the impugned order in detail. The Appellant has not produced anything to interfere with the findings of the GAAR. - AAAR
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