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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The CESTAT held that the transactions do not constitute "Supply of Tangible Goods Service" u/s 65(105)(zzzzj) of the Finance Act, 1994. The Appellant had possession, control, and right to use the packaging material once delivered by Volvo. Volvo's access to information did not confer control or possession over the material. The Appellant could use the material as deemed fit, was liable for damages, and had more than mere custody. The CESTAT relied on the coordinate bench decision in CARAVEL LOGISTICS PVT. LTD. case applying the Supreme Court's five-fold test in BSNL case. Consequently, the appeal was allowed.
The CESTAT held that the transactions do not constitute "Supply of Tangible Goods Service" u/s 65(105)(zzzzj) of the Finance Act, 1994. The Appellant had possession, control, and right to use the packaging material once delivered by Volvo. Volvo's access to information did not confer control or possession over the material. The Appellant could use the material as deemed fit, was liable for damages, and had more than mere custody. The CESTAT relied on the coordinate bench decision in CARAVEL LOGISTICS PVT. LTD. case applying the Supreme Court's five-fold test in BSNL case. Consequently, the appeal was allowed.
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