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...
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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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
CESTAT held that the extended period of limitation was wrongly invoked in the first show cause notice. The service tax demand on amounts received from foreign counterparts under reverse charge mechanism is upheld within the normal limitation period. The appellant's incorrect understanding of tax law was deemed a reasonable cause. All penalties were set aside under section 80. The appeal was partially allowed, with the matter remanded to the Commissioner for calculating and appropriating tax and interest payments already made.
CESTAT held that the extended period of limitation was wrongly invoked in the first show cause notice. The service tax demand on amounts received from foreign counterparts under reverse charge mechanism is upheld within the normal limitation period. The appellant's incorrect understanding of tax law was deemed a reasonable cause. All penalties were set aside under section 80. The appeal was partially allowed, with the matter remanded to the Commissioner for calculating and appropriating tax and interest payments already made.
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