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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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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