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 registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
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