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 held that intermediary services related to goods became taxable from 01.10.2014 following amendments to POPS Rules, 2012. Design and development services were determined to be export of services as the place of provision was located outside India, with no third-party involvement. Given voluntary tax registration, service tax compliance, and absence of fraudulent intent, the tribunal found no grounds for extended limitation period. The demand for service tax was consequently set aside, favoring the appellant's position on service classification and tax treatment.
CESTAT held that intermediary services related to goods became taxable from 01.10.2014 following amendments to POPS Rules, 2012. Design and development services were determined to be export of services as the place of provision was located outside India, with no third-party involvement. Given voluntary tax registration, service tax compliance, and absence of fraudulent intent, the tribunal found no grounds for extended limitation period. The demand for service tax was consequently set aside, favoring the appellant's position on service classification and tax treatment.
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