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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Applicability of GST - Benefit of exemption - Supply of Services by Residents’ Welfare Association (RWA) - The case involved an appeal by a Residents' Welfare Association (RWA) regarding the applicability of GST on contributions to a corpus fund and electricity charges. The RWA argued that GST should be levied only when funds are utilized and that electricity charges should be taxed at the time of actual consumption. However, the authority ruled that contributions to the corpus fund constitute advance payments for future services, hence subject to GST upon collection. Similarly, electricity charges bundled with maintenance services are treated as a composite supply, attracting GST on the entire maintenance charge. The appeal was rejected, affirming the initial ruling of the West Bengal Advance Ruling Authority.
Applicability of GST - Benefit of exemption - Supply of Services by Residents’ Welfare Association (RWA) - The case involved an appeal by a Residents' Welfare Association (RWA) regarding the applicability of GST on contributions to a corpus fund and electricity charges. The RWA argued that GST should be levied only when funds are utilized and that electricity charges should be taxed at the time of actual consumption. However, the authority ruled that contributions to the corpus fund constitute advance payments for future services, hence subject to GST upon collection. Similarly, electricity charges bundled with maintenance services are treated as a composite supply, attracting GST on the entire maintenance charge. The appeal was rejected, affirming the initial ruling of the West Bengal Advance Ruling Authority.
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