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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Supply of Goods or services - Sale of Demo Cars - Reimbursement of Loss on Sale of Demo Car - The AAR noted that the classification of the demo vehicle at the point of sale remains consistent with its classification at the point of purchase. The tax rate applicable at the time of sale would be the same as that applied at the time of its inward supply, aligning with Sections 8702 and 8703 of the Customs Tariff Act, 1975. - The Authority held that the reimbursement amount for the loss on the sale of demo cars from Mercedes Benz constitutes a supply of services. Specifically, this reimbursement is considered a service of 'agreeing to tolerate an act' under GST, which is taxable.
Supply of Goods or services - Sale of Demo Cars - Reimbursement of Loss on Sale of Demo Car - The AAR noted that the classification of the demo vehicle at the point of sale remains consistent with its classification at the point of purchase. The tax rate applicable at the time of sale would be the same as that applied at the time of its inward supply, aligning with Sections 8702 and 8703 of the Customs Tariff Act, 1975. - The Authority held that the reimbursement amount for the loss on the sale of demo cars from Mercedes Benz constitutes a supply of services. Specifically, this reimbursement is considered a service of 'agreeing to tolerate an act' under GST, which is taxable.
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