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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Input tax credit under the WBGST Act need not be reversed by a recipient where payment is reduced due to financial/commercial credit notes issued for secondary/post-sale discounts, because such credit notes do not reduce the original transaction value or the supplier's tax liability and therefore do not reduce tax charged. A manufacturer's post-sale discount to a dealer is not "consideration" for the dealer's onward supply to an end customer where there is no manufacturer-end customer agreement and the discount merely reduces the dealer's sale price; consequently, no additional GST consequence arises on that ground. Where the manufacturer has an agreement with an end customer and funds the dealer's discounted sale, the discount forms part of consideration for the dealer's supply to the end customer, affecting valuation accordingly. Post-sale discounts are not consideration for promotional services unless specific services and consideration are contractually defined, in which case GST applies to that service supply.
Input tax credit under the WBGST Act need not be reversed by a recipient where payment is reduced due to financial/commercial credit notes issued for secondary/post-sale discounts, because such credit notes do not reduce the original transaction value or the supplier's tax liability and therefore do not reduce tax charged. A manufacturer's post-sale discount to a dealer is not "consideration" for the dealer's onward supply to an end customer where there is no manufacturer-end customer agreement and the discount merely reduces the dealer's sale price; consequently, no additional GST consequence arises on that ground. Where the manufacturer has an agreement with an end customer and funds the dealer's discounted sale, the discount forms part of consideration for the dealer's supply to the end customer, affecting valuation accordingly. Post-sale discounts are not consideration for promotional services unless specific services and consideration are contractually defined, in which case GST applies to that service supply.
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