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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The case involved classification of services provided by the Appellant to M/s. Jindal Stainless Steel Ltd. as either manpower recruitment or business auxiliary service. The Tribunal held that the services rendered by the Appellant for processing and manufacturing did not qualify as "manpower recruitment or supply agency service" but fell under business auxiliary service, exempt from service tax. The demand for service tax based on accounting errors was remanded for clarification. The demand for service tax on services rendered as a sub-contractor was restricted to the period after 23.08.2007. The Tribunal set aside penalties and disposed of the appeal.
The case involved classification of services provided by the Appellant to M/s. Jindal Stainless Steel Ltd. as either manpower recruitment or business auxiliary service. The Tribunal held that the services rendered by the Appellant for processing and manufacturing did not qualify as "manpower recruitment or supply agency service" but fell under business auxiliary service, exempt from service tax. The demand for service tax based on accounting errors was remanded for clarification. The demand for service tax on services rendered as a sub-contractor was restricted to the period after 23.08.2007. The Tribunal set aside penalties and disposed of the appeal.
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