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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
CESTAT analyzed the taxability of conversion charges under a job work agreement. The tribunal determined that the interest and depreciation payments did not constitute a rental service. The key finding was that the agreement was exclusively for manufacturing goods, not renting immovable property. The tribunal held that the conversion charges were not consideration for a service, but part of a manufacturing activity. Consequently, the service tax demand was rejected, and the appeals were allowed, affirming that the transaction did not meet the criteria for service tax under the Finance Act, 1994.
CESTAT analyzed the taxability of conversion charges under a job work agreement. The tribunal determined that the interest and depreciation payments did not constitute a rental service. The key finding was that the agreement was exclusively for manufacturing goods, not renting immovable property. The tribunal held that the conversion charges were not consideration for a service, but part of a manufacturing activity. Consequently, the service tax demand was rejected, and the appeals were allowed, affirming that the transaction did not meet the criteria for service tax under the Finance Act, 1994.
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