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 Tangible Goods for Use (STGU) - activity of hiring of rigs on charter basis, by the appellants from GGES - The tribunal held that the service does not qualify as STGU since the possession and effective control of the rigs were transferred to Greatship (India). It was found that despite the lessor having certain rights (like inspecting the rigs), such rights did not negate the effective control transferred to the charterer. The demands of service tax under STGU were set aside.
Supply of Tangible Goods for Use (STGU) - activity of hiring of rigs on charter basis, by the appellants from GGES - The tribunal held that the service does not qualify as STGU since the possession and effective control of the rigs were transferred to Greatship (India). It was found that despite the lessor having certain rights (like inspecting the rigs), such rights did not negate the effective control transferred to the charterer. The demands of service tax under STGU were set aside.
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