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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Waste dump remediation and legacy waste processing services, involving excavation, segregation, scientific disposal and conversion into RDF, compost, grit and inert fractions, were classified under SAC 9994 for sewage, waste collection, treatment, disposal and other environmental protection services, and held taxable at 18%. The supply to Goa Waste Management Corporation was nevertheless treated as pure services, because no goods were involved and the activity related to solid waste management and bio-remediation, a municipal function under Article 243W; exemption under Sl. No. 3 of Notification No. 12/2017-CT was therefore available. A separate query on the recipient's status was declined as outside the scope of advance ruling jurisdiction under Section 97(2).
Waste dump remediation and legacy waste processing services, involving excavation, segregation, scientific disposal and conversion into RDF, compost, grit and inert fractions, were classified under SAC 9994 for sewage, waste collection, treatment, disposal and other environmental protection services, and held taxable at 18%. The supply to Goa Waste Management Corporation was nevertheless treated as pure services, because no goods were involved and the activity related to solid waste management and bio-remediation, a municipal function under Article 243W; exemption under Sl. No. 3 of Notification No. 12/2017-CT was therefore available. A separate query on the recipient's status was declined as outside the scope of advance ruling jurisdiction under Section 97(2).
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