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 HC determined that BRPNNL, a public limited company, does not qualify as a governmental authority and cannot claim exemption from service tax. The court held that the 'centage' received by the petitioner constitutes taxable services under the Finance Act, 1994. The extended period of limitation was justified due to willful suppression of facts and intent to evade service tax. The court directed the petitioner to pursue statutory remedies through an appeal under Section 86 of the Finance Act, 1994, with potential consideration of limitation periods spent in the writ application.
The HC determined that BRPNNL, a public limited company, does not qualify as a governmental authority and cannot claim exemption from service tax. The court held that the 'centage' received by the petitioner constitutes taxable services under the Finance Act, 1994. The extended period of limitation was justified due to willful suppression of facts and intent to evade service tax. The court directed the petitioner to pursue statutory remedies through an appeal under Section 86 of the Finance Act, 1994, with potential consideration of limitation periods spent in the writ application.
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