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 supply or not - services of leasing of the land for industrial purposes by SMPK to the applicant - The Appellate Authority for Advance Ruling finds that while the WBAAR ruled on the ownership aspect, it failed to consider all conditions required for exemption under entry 41. They note that the WBAAR's ruling was limited to a single condition and did not provide a comprehensive analysis of the case. As a result, the Appellate Authority deems it necessary to remand the case back to the WBAAR for a fresh decision, considering all aspects of the matter.
Exemption supply or not - services of leasing of the land for industrial purposes by SMPK to the applicant - The Appellate Authority for Advance Ruling finds that while the WBAAR ruled on the ownership aspect, it failed to consider all conditions required for exemption under entry 41. They note that the WBAAR's ruling was limited to a single condition and did not provide a comprehensive analysis of the case. As a result, the Appellate Authority deems it necessary to remand the case back to the WBAAR for a fresh decision, considering all aspects of the matter.
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