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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Section 10(1)(a) of the IGST Act fixes the place of supply where the movement of goods terminates for delivery to the recipient, not when goods are handed to a common carrier or when title passes under contractual terms. As the goods were destined to recipients at locations outside the State, the supply was inter-State, attracting IGST, and not intra-State so as to permit levy of CGST/SGST on the same transaction. The show cause notice seeking CGST/SGST on a supply already exigible to IGST was held arbitrary and contrary to Section 10(1)(a) and was quashed to the extent of the impugned demand; the petition was partly allowed. - HC
Section 10(1)(a) of the IGST Act fixes the place of supply where the movement of goods terminates for delivery to the recipient, not when goods are handed to a common carrier or when title passes under contractual terms. As the goods were destined to recipients at locations outside the State, the supply was inter-State, attracting IGST, and not intra-State so as to permit levy of CGST/SGST on the same transaction. The show cause notice seeking CGST/SGST on a supply already exigible to IGST was held arbitrary and contrary to Section 10(1)(a) and was quashed to the extent of the impugned demand; the petition was partly allowed. - HC
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