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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Deductions made from sub-contractors' bills were held to be consideration for taxable business support services, not mere reimbursement of CSR or labour welfare . The Tribunal found that the appellant produced no material to show that the recoveries represented actual expenditure incurred on behalf of the contractors' workmen, and the uniform percentage deduction from bill value indicated a quid pro quo for administrative and operational support. The plea of double taxation failed because the contractors' construction service and the appellant's separate support service were distinct taxable activities. The extended period of limitation was also upheld, as the recoveries were not disclosed in returns and the change in nomenclature after audit supported suppression of facts with intent to evade tax.
Deductions made from sub-contractors' bills were held to be consideration for taxable business support services, not mere reimbursement of CSR or labour welfare . The Tribunal found that the appellant produced no material to show that the recoveries represented actual expenditure incurred on behalf of the contractors' workmen, and the uniform percentage deduction from bill value indicated a quid pro quo for administrative and operational support. The plea of double taxation failed because the contractors' construction service and the appellant's separate support service were distinct taxable activities. The extended period of limitation was also upheld, as the recoveries were not disclosed in returns and the change in nomenclature after audit supported suppression of facts with intent to evade tax.
Note: It is a system-generated summary and is for quick reference only.