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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Input tax credit was allowed on inputs and input services used to construct a concrete VCV tower supporting the VCV line for manufacture of EHV cables. The Authority held that the controlling question under section 17(5)(c) and (d) was whether the tower was foundation or structural support of plant and machinery. As the tower was indispensable for holding, stabilising and supporting the vertically laid manufacturing line and maintaining its integrity and efficiency, it fell within the Explanation to section 17 as plant and machinery. The exclusion for land, building or other civil structures was held not to cover such structural support, so the blocked-credit bar did not apply.
Input tax credit was allowed on inputs and input services used to construct a concrete VCV tower supporting the VCV line for manufacture of EHV cables. The Authority held that the controlling question under section 17(5)(c) and (d) was whether the tower was foundation or structural support of plant and machinery. As the tower was indispensable for holding, stabilising and supporting the vertically laid manufacturing line and maintaining its integrity and efficiency, it fell within the Explanation to section 17 as plant and machinery. The exclusion for land, building or other civil structures was held not to cover such structural support, so the blocked-credit bar did not apply.
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