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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NSDC-approved training partners conducting NSQF-aligned digital marketing courses were treated as supplying training services exempt under Entry 69 of Notification No. 12/2017-CT(R), because the services fell within the skill development framework covered by the notification. After Notification No. 08/2024-CT(R), NCVET-accredited training bodies and NSDC-approved training partners were treated as separate categories, so the applicant could not claim the NCVET route merely because the course was NSQF-aligned. The exemption for the intervening period was therefore unavailable on the notification wording, but the tax position for that period was directed to be regularised on an as is where is basis, with no tax recoverable if unpaid and no refund if already paid.
NSDC-approved training partners conducting NSQF-aligned digital marketing courses were treated as supplying training services exempt under Entry 69 of Notification No. 12/2017-CT(R), because the services fell within the skill development framework covered by the notification. After Notification No. 08/2024-CT(R), NCVET-accredited training bodies and NSDC-approved training partners were treated as separate categories, so the applicant could not claim the NCVET route merely because the course was NSQF-aligned. The exemption for the intervening period was therefore unavailable on the notification wording, but the tax position for that period was directed to be regularised on an as is where is basis, with no tax recoverable if unpaid and no refund if already paid.
Note: It is a system-generated summary and is for quick reference only.