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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Construction of residential villas under direct buyer agreements remains a taxable supply of services even where the actual building work is fully outsourced, because the promoter retains contractual responsibility and the outsourced work is only a mode of performance. The transaction is treated as a naturally bundled composite supply, with construction of the villa as the principal supply; the specific residential construction entry under Heading 9954(ia) applies over the general works contract entry. For valuation, the notified GST mechanism for construction involving land requires deduction of one-third of the total amount charged as deemed land value, and actual land pricing does not displace that statutory formula.
Construction of residential villas under direct buyer agreements remains a taxable supply of services even where the actual building work is fully outsourced, because the promoter retains contractual responsibility and the outsourced work is only a mode of performance. The transaction is treated as a naturally bundled composite supply, with construction of the villa as the principal supply; the specific residential construction entry under Heading 9954(ia) applies over the general works contract entry. For valuation, the notified GST mechanism for construction involving land requires deduction of one-third of the total amount charged as deemed land value, and actual land pricing does not displace that statutory formula.
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