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 - inclusion of notional cost of drawings and designs supplied free of cost by Maruti to the vendors in the assessable value of parts or components manufactured by vendors - The Tribunal held that the notional cost of drawings and designs supplied free of cost by Maruti could not be included in the assessable value of parts and components manufactured by the vendors. It was observed that these specifications were provided at the 'Request for Quotation' stage for the purpose of short-listing the vendors and were not used in the actual production of the parts or components. The detailed drawings and designs prepared by the vendors, which were essential for the production, were based on their own development and technology support from other companies. - Tribunal allowed all the appeals filed by the vendors.
Valuation - inclusion of notional cost of drawings and designs supplied free of cost by Maruti to the vendors in the assessable value of parts or components manufactured by vendors - The Tribunal held that the notional cost of drawings and designs supplied free of cost by Maruti could not be included in the assessable value of parts and components manufactured by the vendors. It was observed that these specifications were provided at the 'Request for Quotation' stage for the purpose of short-listing the vendors and were not used in the actual production of the parts or components. The detailed drawings and designs prepared by the vendors, which were essential for the production, were based on their own development and technology support from other companies. - Tribunal allowed all the appeals filed by the vendors.
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