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...
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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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Input tax credit was held admissible on works contract input services used to construct foundation and structural support for plant and machinery installed in the factory. The Authority reasoned that section 17(5)(c) blocks credit for works contract services used for immovable property, but the Explanation to section 17 expressly includes the foundation and structural support of apparatus, equipment and machinery within "plant and machinery". Because the RCC and steel structures were used only to support the machines, absorb vibration and ensure stability, they were not treated as excluded civil structures. The applicant was therefore entitled to credit on the impugned services.
Input tax credit was held admissible on works contract input services used to construct foundation and structural support for plant and machinery installed in the factory. The Authority reasoned that section 17(5)(c) blocks credit for works contract services used for immovable property, but the Explanation to section 17 expressly includes the foundation and structural support of apparatus, equipment and machinery within "plant and machinery". Because the RCC and steel structures were used only to support the machines, absorb vibration and ensure stability, they were not treated as excluded civil structures. The applicant was therefore entitled to credit on the impugned services.
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