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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Academic coaching for students of Standards 5 to 12 was treated as supplementary tuition, not as services supplied by an educational institution. The Authority found that the activity did not amount to pre-school education, education up to higher secondary level or equivalent, curriculum-based education leading to a recognised qualification, or approved vocational education. As the applicant did not fall within the definition of "educational institution" under the exemption notification, Entry 66 exemption was unavailable. The service was therefore classified as commercial training and coaching under SAC 999293 and held taxable at 18% GST.
Academic coaching for students of Standards 5 to 12 was treated as supplementary tuition, not as services supplied by an educational institution. The Authority found that the activity did not amount to pre-school education, education up to higher secondary level or equivalent, curriculum-based education leading to a recognised qualification, or approved vocational education. As the applicant did not fall within the definition of "educational institution" under the exemption notification, Entry 66 exemption was unavailable. The service was therefore classified as commercial training and coaching under SAC 999293 and held taxable at 18% GST.
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