TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.
Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
