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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Provision of canteen and employee transportation facilities was treated as activity in the course of business, with two separate supplies identified: service from the third-party provider to the employer, and outward supply from the employer to employees where amounts were recovered by salary deduction. The recovered portion was held to be consideration liable to GST, while only the employer-borne concession was treated as a perquisite. The employee transport arrangement was not accepted as exempt non-air-conditioned contract carriage under Notification No. 12/2017, since it was characterised as vehicle hiring with operator. Input tax credit was also denied because employee transportation was held to be used for personal consumption under section 17(5)(g).
Provision of canteen and employee transportation facilities was treated as activity in the course of business, with two separate supplies identified: service from the third-party provider to the employer, and outward supply from the employer to employees where amounts were recovered by salary deduction. The recovered portion was held to be consideration liable to GST, while only the employer-borne concession was treated as a perquisite. The employee transport arrangement was not accepted as exempt non-air-conditioned contract carriage under Notification No. 12/2017, since it was characterised as vehicle hiring with operator. Input tax credit was also denied because employee transportation was held to be used for personal consumption under section 17(5)(g).
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