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 CESTAT held that the advertisement charges collected by the appellant as reimbursement expense cannot be included in the gross value of franchise service. The revenue's case was based on Rule 5(1) and 5(2) of the Service Tax (Determination of Value) Rules, 2006, which were held unconstitutional and ultra vires the Finance Act, 1994. The advertisement expenses were ultimately borne by the franchisees as part of their business expenses and cannot be included in the gross value of franchise service. Consequently, the impugned order allowing the revenue's appeal was set aside, and the appeal was allowed.
The CESTAT held that the advertisement charges collected by the appellant as reimbursement expense cannot be included in the gross value of franchise service. The revenue's case was based on Rule 5(1) and 5(2) of the Service Tax (Determination of Value) Rules, 2006, which were held unconstitutional and ultra vires the Finance Act, 1994. The advertisement expenses were ultimately borne by the franchisees as part of their business expenses and cannot be included in the gross value of franchise service. Consequently, the impugned order allowing the revenue's appeal was set aside, and the appeal was allowed.
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