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 under N/N. 9/2009-ST - Service provided by a subcontractor to a unit located in SEZ - The appellant, subcontracted by a main contractor, contested the denial of exemption by the Adjudicating Authority based on procedural grounds. The Appellate Tribunal, after considering submissions and relevant legal precedents, ruled in favor of the appellant. It affirmed that services provided to a SEZ unit, regardless of the subcontractor's involvement, qualify for exemption under the notification. Additionally, the Tribunal dismissed the requirement of Form A-1 for the period before March 2011 and highlighted the overriding effect of the SEZ Act in exempting services consumed within the SEZ.
Exemption under N/N. 9/2009-ST - Service provided by a subcontractor to a unit located in SEZ - The appellant, subcontracted by a main contractor, contested the denial of exemption by the Adjudicating Authority based on procedural grounds. The Appellate Tribunal, after considering submissions and relevant legal precedents, ruled in favor of the appellant. It affirmed that services provided to a SEZ unit, regardless of the subcontractor's involvement, qualify for exemption under the notification. Additionally, the Tribunal dismissed the requirement of Form A-1 for the period before March 2011 and highlighted the overriding effect of the SEZ Act in exempting services consumed within the SEZ.
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