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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CESTAT remanded a service tax dispute concerning a Town Panchayat's renting of immovable property. The case centered on whether municipal services qualified for tax exemption under sovereign functions. Following precedents from Madras HC in Cuddalore Municipality and St. Thomas Mount cases, the Tribunal determined that a detailed examination was necessary to establish if the services constituted sovereign functions. The matter was remanded to the Adjudicating Authority for fresh consideration, specifically to analyze the nature of services provided and their classification under sovereign functions. The extended period of limitation and local authority status were key elements requiring reassessment.
CESTAT remanded a service tax dispute concerning a Town Panchayat's renting of immovable property. The case centered on whether municipal services qualified for tax exemption under sovereign functions. Following precedents from Madras HC in Cuddalore Municipality and St. Thomas Mount cases, the Tribunal determined that a detailed examination was necessary to establish if the services constituted sovereign functions. The matter was remanded to the Adjudicating Authority for fresh consideration, specifically to analyze the nature of services provided and their classification under sovereign functions. The extended period of limitation and local authority status were key elements requiring reassessment.
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