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...
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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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Taxation of goods in a works contract is governed by the principle that the taxable event is the transfer of property in goods incorporated in the works and the taxable value is the value of those goods at the time of incorporation. Applying the transformation and marketability tests, fabricated steel superstructures/triangulated girders were held to be commercially distinct, marketable goods whose value included embedded fabrication, transportation, launching and erection costs; accordingly they were taxable as unspecified goods and most claimed fabrication-related deductions were disallowed. Reassessment under Section 31 BVAT was held within jurisdiction where recorded satisfaction existed on the material before the assessing officer.
Taxation of goods in a works contract is governed by the principle that the taxable event is the transfer of property in goods incorporated in the works and the taxable value is the value of those goods at the time of incorporation. Applying the transformation and marketability tests, fabricated steel superstructures/triangulated girders were held to be commercially distinct, marketable goods whose value included embedded fabrication, transportation, launching and erection costs; accordingly they were taxable as unspecified goods and most claimed fabrication-related deductions were disallowed. Reassessment under Section 31 BVAT was held within jurisdiction where recorded satisfaction existed on the material before the assessing officer.
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