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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License Fees, Documentation Fees, and Computer Software. The Tribunal held that these amounts were towards amortization disclosure required under Indian Accounting Standard (Ind AS) 38A and not consideration for receipt of any service during the disputed period. The appellant did not receive any service from foreign vendors during this period for which they were required to pay service tax on reverse charge basis. The demand treating these services under Transfer of Intellectual Property Rights Service was unsustainable. The findings that overseas vendors carried out activities for consideration were incorrect as no activity was performed by them for these amounts during the disputed period. These were mere book entries towards license fees, documentation fees, computer software, etc. As the demand was set aside on merits, the Tribunal did not record separate findings on the issue of limitation or penalty.
License Fees, Documentation Fees, and Computer Software. The Tribunal held that these amounts were towards amortization disclosure required under Indian Accounting Standard (Ind AS) 38A and not consideration for receipt of any service during the disputed period. The appellant did not receive any service from foreign vendors during this period for which they were required to pay service tax on reverse charge basis. The demand treating these services under Transfer of Intellectual Property Rights Service was unsustainable. The findings that overseas vendors carried out activities for consideration were incorrect as no activity was performed by them for these amounts during the disputed period. These were mere book entries towards license fees, documentation fees, computer software, etc. As the demand was set aside on merits, the Tribunal did not record separate findings on the issue of limitation or penalty.
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