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 determined that the technology assistance provided by the Research Center to its Division does not constitute a taxable service. The tribunal found that the Forsoc Technology Center (FTC) is an integral part of the appellant's organization, and the R&D expenditures cannot be considered a taxable service payment to the holding company. Consequently, the service tax demand for the period from April 2010 to March 2012 was set aside, with the principle of consistency applied to subsequent periods. The appellate authority ruled in favor of the appellant, effectively exempting the transaction from service tax liability.
CESTAT determined that the technology assistance provided by the Research Center to its Division does not constitute a taxable service. The tribunal found that the Forsoc Technology Center (FTC) is an integral part of the appellant's organization, and the R&D expenditures cannot be considered a taxable service payment to the holding company. Consequently, the service tax demand for the period from April 2010 to March 2012 was set aside, with the principle of consistency applied to subsequent periods. The appellate authority ruled in favor of the appellant, effectively exempting the transaction from service tax liability.
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