Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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AAR held that non-monetary benefits/perquisites, including tour packages received by the applicant from a manufacturer for achieving sales targets, constitute a taxable "supply of services" in the course or furtherance of business. No exemption under Notification No. 12/2017-Central Tax (Rate) applies. The applicant is the supplier of sales promotion/business support services and the manufacturer is the recipient; accordingly, the applicant must raise a tax invoice on the manufacturer. For valuation, the value of service is the value of gifts/perquisites/tour packages as reflected in the TDS certificate under section 194R of the Income-tax Act. The applicant may issue invoices on a tax-inclusive basis in terms of rule 35 of the valuation provisions.
AAR held that non-monetary benefits/perquisites, including tour packages received by the applicant from a manufacturer for achieving sales targets, constitute a taxable "supply of services" in the course or furtherance of business. No exemption under Notification No. 12/2017-Central Tax (Rate) applies. The applicant is the supplier of sales promotion/business support services and the manufacturer is the recipient; accordingly, the applicant must raise a tax invoice on the manufacturer. For valuation, the value of service is the value of gifts/perquisites/tour packages as reflected in the TDS certificate under section 194R of the Income-tax Act. The applicant may issue invoices on a tax-inclusive basis in terms of rule 35 of the valuation provisions.
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