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 declared service under Section 66E(e) requires a contractual consideration; pre agreed compensation for idle or underutilised production capacity treated as part of the agreed remuneration qualifies as such consideration and therefore falls within the declared service entry. Under the Place of Provision of Services Rules, the general destination principle applies where services are not directly tied to immovable property, so the place of provision is the location of the service recipient. Because the arrangement concerned manufacture and remuneration for capacity held for a foreign recipient, the service was treated as provided outside India and qualified as export of services, negating the departmental demand.
A declared service under Section 66E(e) requires a contractual consideration; pre agreed compensation for idle or underutilised production capacity treated as part of the agreed remuneration qualifies as such consideration and therefore falls within the declared service entry. Under the Place of Provision of Services Rules, the general destination principle applies where services are not directly tied to immovable property, so the place of provision is the location of the service recipient. Because the arrangement concerned manufacture and remuneration for capacity held for a foreign recipient, the service was treated as provided outside India and qualified as export of services, negating the departmental demand.
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