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's activities relating to field-level data validation of Functional Household Tap Connections, orientation programmes for mission stakeholders, and GIS-based collection and visualization of components of Piped Water Supply Schemes are integrally connected to supply of safe drinking water under JJM. These services fall within functions under Serial No. 11 of the Eleventh Schedule to Art. 243G and Serial No. 5 of the Twelfth Schedule to Art. 243W. As the contracts involve only software development, data management and training, with no supply of goods, they constitute "pure services". Accordingly, they are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
AAR held that the applicant's activities relating to field-level data validation of Functional Household Tap Connections, orientation programmes for mission stakeholders, and GIS-based collection and visualization of components of Piped Water Supply Schemes are integrally connected to supply of safe drinking water under JJM. These services fall within functions under Serial No. 11 of the Eleventh Schedule to Art. 243G and Serial No. 5 of the Twelfth Schedule to Art. 243W. As the contracts involve only software development, data management and training, with no supply of goods, they constitute "pure services". Accordingly, they are classifiable under Sl. No. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
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