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 for the State PHE Directorate under the JJM-comprising digitalisation and monitoring of water supply schemes, GIS-based data management, development and enhancement of software/applications (including Jal Mitra and UTWID generation), technical consultancy, documentation, and orientation programmes-constitute "pure services" with no supply of goods. These services are directly in relation to supply of safe drinking water, a function covered under serial no. 11 of the Eleventh Schedule to Art. 243G and serial no. 5 of the Twelfth Schedule to Art. 243W. Accordingly, the services are classifiable under serial no. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
AAR held that the applicant's activities for the State PHE Directorate under the JJM-comprising digitalisation and monitoring of water supply schemes, GIS-based data management, development and enhancement of software/applications (including Jal Mitra and UTWID generation), technical consultancy, documentation, and orientation programmes-constitute "pure services" with no supply of goods. These services are directly in relation to supply of safe drinking water, a function covered under serial no. 11 of the Eleventh Schedule to Art. 243G and serial no. 5 of the Twelfth Schedule to Art. 243W. Accordingly, the services are classifiable under serial no. 3 of Notification No. 12/2017-CT (Rate) and are exempt from GST.
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