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 appellant, engaged in providing a bouquet of services, was held liable to pay service tax on Renting of Immovable Property Service (RIPS). The tribunal rejected the appellant's claim of rendering sovereign functions, emphasizing that the appellant operates as a commercial entity and cannot selectively avoid tax liability. The agreement characterized as a commercial arrangement, with rental termed as user charges or license fees, does not exempt the appellant from service tax. The invocation of the extended period of limitation was upheld, as the appellant was aware of its tax obligations, having registered and paid service tax on other services. The attempt to circumvent tax liability on RIPS was deemed unjustified, and the appellant's appeal was dismissed in its entirety.
The appellant, engaged in providing a bouquet of services, was held liable to pay service tax on Renting of Immovable Property Service (RIPS). The tribunal rejected the appellant's claim of rendering sovereign functions, emphasizing that the appellant operates as a commercial entity and cannot selectively avoid tax liability. The agreement characterized as a commercial arrangement, with rental termed as user charges or license fees, does not exempt the appellant from service tax. The invocation of the extended period of limitation was upheld, as the appellant was aware of its tax obligations, having registered and paid service tax on other services. The attempt to circumvent tax liability on RIPS was deemed unjustified, and the appellant's appeal was dismissed in its entirety.
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