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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Eligibility to exemption - Taxability of emergency response services provided to government entities - The tribunal upheld the exemption for Dial 108, Dial 102, and Dial 104 projects under Notification No. 25/2012–ST, affirming these services were provided to the government by way of public health and were thus exempt from service tax. - The tribunal recognized the tax liability for the Dial 100 Project, noting that the service tax for this project had been duly paid by the appellant, including the applicable interest, before the issuance of the show cause notice. - The tribunal also recognized the appellant's good faith belief in their exemption status, leading to the setting aside of penalties for the alleged non-compliance.
Eligibility to exemption - Taxability of emergency response services provided to government entities - The tribunal upheld the exemption for Dial 108, Dial 102, and Dial 104 projects under Notification No. 25/2012–ST, affirming these services were provided to the government by way of public health and were thus exempt from service tax. - The tribunal recognized the tax liability for the Dial 100 Project, noting that the service tax for this project had been duly paid by the appellant, including the applicable interest, before the issuance of the show cause notice. - The tribunal also recognized the appellant's good faith belief in their exemption status, leading to the setting aside of penalties for the alleged non-compliance.
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