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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Appellant is not a Governmental Authority exempted under Notification No. 25/2012-ST. Renting of immovable property and Mandap Keeper services provided by Appellant are taxable. Show cause notice was not vague. Appellant failed to prove community centres were given for religious activities. Appellant is neither a Government nor local authority. Extended period of limitation correctly invoked. Penalties u/s 78 set aside, but upheld u/s 77 for non-registration and non-filing of returns. Appeal allowed in part by CESTAT.
Appellant is not a Governmental Authority exempted under Notification No. 25/2012-ST. Renting of immovable property and Mandap Keeper services provided by Appellant are taxable. Show cause notice was not vague. Appellant failed to prove community centres were given for religious activities. Appellant is neither a Government nor local authority. Extended period of limitation correctly invoked. Penalties u/s 78 set aside, but upheld u/s 77 for non-registration and non-filing of returns. Appeal allowed in part by CESTAT.
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