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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Recovery of Service Tax - Business auxiliary services - sale and purchase of cargo space - The Appellate Tribunal found that the appellant's activities of buying and selling cargo space were transactions of sale, not services rendered. It disagreed with the Commissioner's interpretation that any activity other than sale of goods constitutes a service. The Tribunal held that the appellant's transactions did not fall under the purview of taxable services and thus set aside the service tax demands.
Recovery of Service Tax - Business auxiliary services - sale and purchase of cargo space - The Appellate Tribunal found that the appellant's activities of buying and selling cargo space were transactions of sale, not services rendered. It disagreed with the Commissioner's interpretation that any activity other than sale of goods constitutes a service. The Tribunal held that the appellant's transactions did not fall under the purview of taxable services and thus set aside the service tax demands.
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