Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
ITAT dismissed assessee's appeal on two grounds. Regarding transfer pricing adjustment on corporate guarantee commission, Tribunal upheld TPO's determination that providing corporate guarantees to associated enterprises constitutes international transactions requiring arm's length pricing. TPO properly applied comparable uncontrolled price method using bank guarantee commission rates with prudent 0.5% downward adjustment for risk differentials. Assessee failed to demonstrate any infirmity in TPO's methodology or comparable selection. On income classification, Tribunal confirmed DRP's ruling that interest on income-tax refund belongs under "Income from Other Sources" rather than business income, as such interest constitutes statutory compensation for delayed refund without nexus to business operations, not arising from commercial activities.
ITAT dismissed assessee's appeal on two grounds. Regarding transfer pricing adjustment on corporate guarantee commission, Tribunal upheld TPO's determination that providing corporate guarantees to associated enterprises constitutes international transactions requiring arm's length pricing. TPO properly applied comparable uncontrolled price method using bank guarantee commission rates with prudent 0.5% downward adjustment for risk differentials. Assessee failed to demonstrate any infirmity in TPO's methodology or comparable selection. On income classification, Tribunal confirmed DRP's ruling that interest on income-tax refund belongs under "Income from Other Sources" rather than business income, as such interest constitutes statutory compensation for delayed refund without nexus to business operations, not arising from commercial activities.
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TaxTMI 
TaxTMI 
of 4916 
