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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HC ruled on VAT applicability to Set Top Boxes (STBs) under Karnataka VAT Act 2003. STBs were determined to be goods under section 2(15), capable of exclusive subscriber use with transfer rights for Rs. 2,000 consideration. Court upheld concurrent findings that STBs constitute taxable goods despite service component, rejecting argument of mutual exclusivity between service tax and VAT. Assessees' contention that government notification dated 15.03.2021 couldn't have retrospective effect was dismissed. HC affirmed that tax regime during transition between 2003 Act's repeal and 2017 Act's enactment wasn't intended as tax haven. Revision petition challenging VAT assessment on STBs dismissed, confirming dual applicability of service tax and VAT based on distinct taxing incidents.
HC ruled on VAT applicability to Set Top Boxes (STBs) under Karnataka VAT Act 2003. STBs were determined to be goods under section 2(15), capable of exclusive subscriber use with transfer rights for Rs. 2,000 consideration. Court upheld concurrent findings that STBs constitute taxable goods despite service component, rejecting argument of mutual exclusivity between service tax and VAT. Assessees' contention that government notification dated 15.03.2021 couldn't have retrospective effect was dismissed. HC affirmed that tax regime during transition between 2003 Act's repeal and 2017 Act's enactment wasn't intended as tax haven. Revision petition challenging VAT assessment on STBs dismissed, confirming dual applicability of service tax and VAT based on distinct taxing incidents.
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