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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Service tax demand with interest and penalty on reimbursement cost received from landowner for constructing flats under Joint Development Agreement set aside. Reimbursement between joint venture partners not liable to service tax as held in Mormugao Port Trust case. Extended period of limitation not invokable when service tax held not payable and department had full knowledge of facts. Appellate Tribunal allows appeal and sets aside impugned order.
Service tax demand with interest and penalty on reimbursement cost received from landowner for constructing flats under Joint Development Agreement set aside. Reimbursement between joint venture partners not liable to service tax as held in Mormugao Port Trust case. Extended period of limitation not invokable when service tax held not payable and department had full knowledge of facts. Appellate Tribunal allows appeal and sets aside impugned order.
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