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 services provided by the applicant to designated Municipal Corporations and Municipalities are rendered to "local authorities" under s.2(69) CGST Act, as these bodies are "Municipalities" under Arts. 243P and 243Q of the Constitution. The activities are in relation to functions entrusted under Arts. 243G and 243W, read with the Eleventh and Twelfth Schedules. However, since certain contracts involve supply of spare parts and other goods, the transactions constitute composite supplies with maintenance as the principal supply. Exemption under Entry 3 (pure services) of N/N. 12/2017 is inapplicable; exemption, if any, is available only under Entry 3A where the value of goods does not exceed 25% of the total supply.
AAR held that services provided by the applicant to designated Municipal Corporations and Municipalities are rendered to "local authorities" under s.2(69) CGST Act, as these bodies are "Municipalities" under Arts. 243P and 243Q of the Constitution. The activities are in relation to functions entrusted under Arts. 243G and 243W, read with the Eleventh and Twelfth Schedules. However, since certain contracts involve supply of spare parts and other goods, the transactions constitute composite supplies with maintenance as the principal supply. Exemption under Entry 3 (pure services) of N/N. 12/2017 is inapplicable; exemption, if any, is available only under Entry 3A where the value of goods does not exceed 25% of the total supply.
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