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 - real estate agent - collecting transfer/administrative charges - Referring to precedents, the Tribunal affirmed that charges for changes in property ownership records are not causative factors for sale or purchase transactions. They emphasized that the appellant operated on a principal-to-principal basis with buyers, old or new, and thus, did not qualify as a real estate agent in the context of the service tax law. - The Tribunal concluded that the transfer/administrative charges collected by the appellant were not liable to service tax under the category of real estate agent services
Levy of service tax - real estate agent - collecting transfer/administrative charges - Referring to precedents, the Tribunal affirmed that charges for changes in property ownership records are not causative factors for sale or purchase transactions. They emphasized that the appellant operated on a principal-to-principal basis with buyers, old or new, and thus, did not qualify as a real estate agent in the context of the service tax law. - The Tribunal concluded that the transfer/administrative charges collected by the appellant were not liable to service tax under the category of real estate agent services
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