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 supply of instant premix tea sachets bundled with various teas as an introductory offer does not qualify as a composite supply under s.2(30) CGST Act, as the items are not naturally bundled, premix tea is not ancillary or integral to the other teas, and its removal does not affect the nature of the supply. The transaction satisfies all conditions of "mixed supply" under s.2(74), being multiple independent supplies made together for a single price. Accordingly, the bundle is treated as a mixed supply taxable at the highest applicable rate among the bundled goods, which in this case is 5% GST, though the Act is silent on the applicable HSN where rates are identical.
AAR held that supply of instant premix tea sachets bundled with various teas as an introductory offer does not qualify as a composite supply under s.2(30) CGST Act, as the items are not naturally bundled, premix tea is not ancillary or integral to the other teas, and its removal does not affect the nature of the supply. The transaction satisfies all conditions of "mixed supply" under s.2(74), being multiple independent supplies made together for a single price. Accordingly, the bundle is treated as a mixed supply taxable at the highest applicable rate among the bundled goods, which in this case is 5% GST, though the Act is silent on the applicable HSN where rates are identical.
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