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 jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
Advance ruling jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
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