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 ruled in favor of the appellant cricket franchise, setting aside multiple service tax demands. The Tribunal determined that Central Rights Income from BCCI-IPL did not constitute taxable Business Support Services as no service was provided between franchise agreement members. Similarly, payments to overseas cricket professionals for promotional activities were deemed primarily for playing cricket and thus not taxable. Player release fees paid to Cricket Australia and player transfer fees received from other franchisees were held not taxable under Manpower Recruitment or Supply Agency Services since neither cricket boards nor the appellant were engaged in providing such services. Additionally, the Tribunal found the demand barred by limitation as the Department was previously aware of all relevant facts.
CESTAT ruled in favor of the appellant cricket franchise, setting aside multiple service tax demands. The Tribunal determined that Central Rights Income from BCCI-IPL did not constitute taxable Business Support Services as no service was provided between franchise agreement members. Similarly, payments to overseas cricket professionals for promotional activities were deemed primarily for playing cricket and thus not taxable. Player release fees paid to Cricket Australia and player transfer fees received from other franchisees were held not taxable under Manpower Recruitment or Supply Agency Services since neither cricket boards nor the appellant were engaged in providing such services. Additionally, the Tribunal found the demand barred by limitation as the Department was previously aware of all relevant facts.
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