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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Overseas service providers provided data collection services to the respondent. The activities were merely data collection through questionnaires, with no research or interpretation. The raw data was supplied back to the respondent for further analysis. These services cannot be classified as "Market Research Services" as there was no research involved. The services were akin to an architect outsourcing land surveying, which is an input but not architectural services itself. Similarly, a tour operator hiring buses does not make it a bus service. The classification as "Online Information and Database Access or Retrieval Services" is irrelevant. The demand to classify data collection as market research cannot be sustained. Additionally, the extended period of limitation for issuing the show cause notice cannot be invoked as there was no mala fide intent or evasion. Any service tax payable would have been available as CENVAT credit, making it revenue neutral. The revenue appeal was dismissed by the CESTAT.
Overseas service providers provided data collection services to the respondent. The activities were merely data collection through questionnaires, with no research or interpretation. The raw data was supplied back to the respondent for further analysis. These services cannot be classified as "Market Research Services" as there was no research involved. The services were akin to an architect outsourcing land surveying, which is an input but not architectural services itself. Similarly, a tour operator hiring buses does not make it a bus service. The classification as "Online Information and Database Access or Retrieval Services" is irrelevant. The demand to classify data collection as market research cannot be sustained. Additionally, the extended period of limitation for issuing the show cause notice cannot be invoked as there was no mala fide intent or evasion. Any service tax payable would have been available as CENVAT credit, making it revenue neutral. The revenue appeal was dismissed by the CESTAT.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
