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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Appellate tribunal addressed taxability of various receipts of an agent: performance or target incentives paid by airlines were held not to constitute consideration for a taxable service and demand cancelled; freight brokerage/commission on freight could not be classified as business auxiliary service and demand set aside; reimbursements of expenses reimbursed after payment fall outside taxable value (85% abatement applicable) and related demand disallowed; alleged labour charge liability based on assumptions without verification was unsustainable; invocation of extended period failed for lack of suppression with intent to evade, and consequential interest and penalty demands were also dismissed.
Appellate tribunal addressed taxability of various receipts of an agent: performance or target incentives paid by airlines were held not to constitute consideration for a taxable service and demand cancelled; freight brokerage/commission on freight could not be classified as business auxiliary service and demand set aside; reimbursements of expenses reimbursed after payment fall outside taxable value (85% abatement applicable) and related demand disallowed; alleged labour charge liability based on assumptions without verification was unsustainable; invocation of extended period failed for lack of suppression with intent to evade, and consequential interest and penalty demands were also dismissed.
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