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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Exemption from GST - Scope of the Term "Applicant" for seeking advance Ruling - The case involved a government authority seeking a ruling on the applicability of GST exemption to various services received for conducting examinations. The Authority for Advance Ruling (AAR) initially dismissed the application, citing the Appellant's status as a service recipient rather than a supplier. However, the Appellate Authority (AAAR) overturned this decision, emphasizing the broad interpretation of "applicant" under GST law. They referenced a judgment of the Hon'ble High Court, Calcutta, which underscored the inclusive nature of the term "applicant" and directed the AAR to reconsider the application in light of this interpretation. - Matter restored back to AAR for reconsideration.
Exemption from GST - Scope of the Term "Applicant" for seeking advance Ruling - The case involved a government authority seeking a ruling on the applicability of GST exemption to various services received for conducting examinations. The Authority for Advance Ruling (AAR) initially dismissed the application, citing the Appellant's status as a service recipient rather than a supplier. However, the Appellate Authority (AAAR) overturned this decision, emphasizing the broad interpretation of "applicant" under GST law. They referenced a judgment of the Hon'ble High Court, Calcutta, which underscored the inclusive nature of the term "applicant" and directed the AAR to reconsider the application in light of this interpretation. - Matter restored back to AAR for reconsideration.
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