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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Emergency care and life-support courses were treated as structured skill-based training, not public awareness of preventive health or charitable activity under Notification No. 12/2017. The Authority held that training delivered to identifiable participants for consideration, with evaluation, certification and renewal of certificates, did not qualify for exemption under Entry 1, and the same reasoning applied to renewal fees. It also found that the provider was not an educational institution for Entry 66 purposes because the courses were not part of a recognised curriculum or approved vocational education. The services were classified as commercial training and coaching services under SAC 999293 and held taxable at 18%.
Emergency care and life-support courses were treated as structured skill-based training, not public awareness of preventive health or charitable activity under Notification No. 12/2017. The Authority held that training delivered to identifiable participants for consideration, with evaluation, certification and renewal of certificates, did not qualify for exemption under Entry 1, and the same reasoning applied to renewal fees. It also found that the provider was not an educational institution for Entry 66 purposes because the courses were not part of a recognised curriculum or approved vocational education. The services were classified as commercial training and coaching services under SAC 999293 and held taxable at 18%.
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