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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Advance ruling application concerning whether hostel accommodation provided by the applicant's tenant qualifies as a residential dwelling and is exempt under Entry 12/12A was held inadmissible because the queries relate to supplies made by the tenant, not supplies by the applicant, and thus fall outside the scope of advance ruling jurisdiction under the statute. The related question on whether in house food is a composite exempt supply was also rejected as dependent on the inadmissible queries. The applicability of case law to the applicant's facts was held outside permissible advance ruling questions, and any precedent evidence would not assist due to non binding provisions; application rejected under procedural admissibility rules.
Advance ruling application concerning whether hostel accommodation provided by the applicant's tenant qualifies as a residential dwelling and is exempt under Entry 12/12A was held inadmissible because the queries relate to supplies made by the tenant, not supplies by the applicant, and thus fall outside the scope of advance ruling jurisdiction under the statute. The related question on whether in house food is a composite exempt supply was also rejected as dependent on the inadmissible queries. The applicability of case law to the applicant's facts was held outside permissible advance ruling questions, and any precedent evidence would not assist due to non binding provisions; application rejected under procedural admissibility rules.
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