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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A partner's payment of service tax using the partner's registration may be adjusted against the firm's liability because a partner is not a separate legal entity; the adjustment is allowed. The appellant's liability as subcontractor for services including transportation of goods is sustained, but supporting documents submitted must be examined. The impugned rejection of abatement/reconciliation is remanded for fresh consideration and verification of invoices, payment documents and work orders. The authority is directed to recompute service tax on works contract and transportation services after giving the appellant opportunity to produce relevant records.
A partner's payment of service tax using the partner's registration may be adjusted against the firm's liability because a partner is not a separate legal entity; the adjustment is allowed. The appellant's liability as subcontractor for services including transportation of goods is sustained, but supporting documents submitted must be examined. The impugned rejection of abatement/reconciliation is remanded for fresh consideration and verification of invoices, payment documents and work orders. The authority is directed to recompute service tax on works contract and transportation services after giving the appellant opportunity to produce relevant records.
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