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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AAR held that amounts deposited by shippers into an escrow account operated by the applicant for onward remittance to carriers do not constitute "consideration" under Section 7 of the CGST Act, as the sums never accrue to the applicant and are held purely as deposits belonging to the transacting parties. The applicant's only taxable supply is its facilitation service as an intermediary, for which it receives subscription/commission, on which it is already discharging GST. Consequently, no GST is payable on the freight amounts handled through the escrow mechanism, which are outside the scope of supply in the applicant's hands.
AAR held that amounts deposited by shippers into an escrow account operated by the applicant for onward remittance to carriers do not constitute "consideration" under Section 7 of the CGST Act, as the sums never accrue to the applicant and are held purely as deposits belonging to the transacting parties. The applicant's only taxable supply is its facilitation service as an intermediary, for which it receives subscription/commission, on which it is already discharging GST. Consequently, no GST is payable on the freight amounts handled through the escrow mechanism, which are outside the scope of supply in the applicant's hands.
Note: It is a system-generated summary and is for quick reference only.