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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Rebate received from a bank for payment of excise duty through a corporate card was treated by the AAR as a post-transaction monetary adjustment, not consideration for an identifiable supply of goods or services. Because taxable supply under the GST law requires consideration and a quid pro quo, and the rebate merely reduced the applicant's monetary liability, it fell within a transaction in money and outside the scope of supply. The Authority also noted the arrangement operated as short-term financial accommodation, with the rebate functioning as a discount linked to that facility. The rebate was therefore not liable to GST.
Rebate received from a bank for payment of excise duty through a corporate card was treated by the AAR as a post-transaction monetary adjustment, not consideration for an identifiable supply of goods or services. Because taxable supply under the GST law requires consideration and a quid pro quo, and the rebate merely reduced the applicant's monetary liability, it fell within a transaction in money and outside the scope of supply. The Authority also noted the arrangement operated as short-term financial accommodation, with the rebate functioning as a discount linked to that facility. The rebate was therefore not liable to GST.
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