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 Circular provides clarity on time of supply for services in construction of roads and maintenance under the Hybrid Annuity Mode (HAM) model for National Highway Projects. It states that under the HAM model, where payments are staggered over the contract period, the time of supply is determined by the date of invoice issuance or payment receipt, whichever is earlier. If the invoice is not issued as prescribed, the time of supply is the date of service provision or payment receipt. The Circular also clarifies that interest components in payments to the concessionaire should be included in the taxable value. Tax liability arises based on the above principles.
The Circular provides clarity on time of supply for services in construction of roads and maintenance under the Hybrid Annuity Mode (HAM) model for National Highway Projects. It states that under the HAM model, where payments are staggered over the contract period, the time of supply is determined by the date of invoice issuance or payment receipt, whichever is earlier. If the invoice is not issued as prescribed, the time of supply is the date of service provision or payment receipt. The Circular also clarifies that interest components in payments to the concessionaire should be included in the taxable value. Tax liability arises based on the above principles.
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