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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In a real estate anti-profiteering matter, the Tribunal applied a project-wise, area-based method to quantify the benefit of GST input tax credit and upheld the DGAP's computation on the basis that post-GST credit savings had to be passed on to homebuyers. It rejected attempts to restrict the benefit to goods-related credit or to notionally adjust unavailed pre-GST service credit, and treated the respondent's verified statements as admissions that profiteering had occurred. The amount of profiteering was upheld with GST on the excess realisation, and interest was also directed from the date of payment of the last instalment by each buyer.
In a real estate anti-profiteering matter, the Tribunal applied a project-wise, area-based method to quantify the benefit of GST input tax credit and upheld the DGAP's computation on the basis that post-GST credit savings had to be passed on to homebuyers. It rejected attempts to restrict the benefit to goods-related credit or to notionally adjust unavailed pre-GST service credit, and treated the respondent's verified statements as admissions that profiteering had occurred. The amount of profiteering was upheld with GST on the excess realisation, and interest was also directed from the date of payment of the last instalment by each buyer.
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