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 the applicant, operating as a Goods Transport Agency, is entitled to avail full ITC of GST paid on bio-diesel used as fuel in its goods carriages, as the input is used in the course or furtherance of business under Section 16 of CGST Act. Section 17(5) restrictions were found inapplicable since they relate to passenger vehicles, not goods carriages. AAR further held that the applicant may opt to pay GST on GTA services at 12% (18% w.e.f. 22.09.2025) under forward charge in terms of N/N. 11/2017-CT(R), read with N/N. 13/2017-CT(R), and correspondingly claim full ITC, subject to statutory conditions.
AAR held that the applicant, operating as a Goods Transport Agency, is entitled to avail full ITC of GST paid on bio-diesel used as fuel in its goods carriages, as the input is used in the course or furtherance of business under Section 16 of CGST Act. Section 17(5) restrictions were found inapplicable since they relate to passenger vehicles, not goods carriages. AAR further held that the applicant may opt to pay GST on GTA services at 12% (18% w.e.f. 22.09.2025) under forward charge in terms of N/N. 11/2017-CT(R), read with N/N. 13/2017-CT(R), and correspondingly claim full ITC, subject to statutory conditions.
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