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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Key issues regarding invocation of time limitation for raising demand, levy of penalty, exemption from service tax for bundled services related to the game of cricket, and dropping of demands raised under various service categories like business auxiliary service, event management service, mandap keeper service, and renting of immovable property service. It discusses the rationale for not invoking extended period of limitation, exemption from service tax for services rendered by a charitable institution promoting sports, and reasons for dropping demands under different service categories. The adjudicating authority's order is set aside, demands are dropped, and the assessee's appeal is allowed, considering the services are not taxable under the respective categories.
Key issues regarding invocation of time limitation for raising demand, levy of penalty, exemption from service tax for bundled services related to the game of cricket, and dropping of demands raised under various service categories like business auxiliary service, event management service, mandap keeper service, and renting of immovable property service. It discusses the rationale for not invoking extended period of limitation, exemption from service tax for services rendered by a charitable institution promoting sports, and reasons for dropping demands under different service categories. The adjudicating authority's order is set aside, demands are dropped, and the assessee's appeal is allowed, considering the services are not taxable under the respective categories.
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