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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Service of affiliation and inspection fees charged by universities are not covered by the exemption for 'service in connection with admission of students or conduct of examination'; such fees are independent services provided to grant affiliation and precede any admission, which is governed by statutory criteria and institutional infrastructure. The High Court rejects an extended reading of the exemption that would treat affiliation-related services as admission services, endorses the contrary view in the later precedent and holds affiliation fees amenable to GST. The matter is remitted to the Single Judge for determination on any other grounds remaining in dispute.
Service of affiliation and inspection fees charged by universities are not covered by the exemption for 'service in connection with admission of students or conduct of examination'; such fees are independent services provided to grant affiliation and precede any admission, which is governed by statutory criteria and institutional infrastructure. The High Court rejects an extended reading of the exemption that would treat affiliation-related services as admission services, endorses the contrary view in the later precedent and holds affiliation fees amenable to GST. The matter is remitted to the Single Judge for determination on any other grounds remaining in dispute.
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