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Showing 21 to 40 of 521 Records Search Text: service tax medical transcription |
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2021 (5) TMI 338 - ITAT AHMEDABAD TP Adjustment - holding foreign exchange fluctuation gain should not form part of operating income for comparative analysis - HELD THAT:- As clear from the findings of the authorities below that in case of the assessee, the amount of foreign exchange gain are arise out of the revenue transactions - when foreign exchange fluctuation income is an operating income then same has to be taken into consideration while determining ALP of international transactions entered into by assessee - we consider ... ... ...
2020 (9) TMI 1286 - ITAT BANGALORE Disallowances made on account of quality rejects, breakage leakage etc, expired inventory, stock of Genosys, stock difference in error - HELD THAT:- Breakage, Leakage etc - Assessee in order to establish breakage leakage etc had filed a chart showing the ratio of the law is on such breakage to sales during the relevant years which is negligible as compared to huge turnover of assessee. We therefore direct assessee to file identical details for year under consideration to establish the claim in v... ... ...
2024 (7) TMI 631 - ITAT BANGALORE TP adjustment - re- characterisation of the functionality of the Assessee in the Information Technology ( IT ) segment - assessee is a wholly owned Subsidiary of Google International LLC, USA with a registered office in Bangalore and has STPI units at Hyderabad and Gurgaon, and is engaged in the business of providing ITeS services; IT Services; and marketing and distributing Ad Words - HELD THAT:- Appendix I (c ) to the APA of the PB that, the agreements considered between the assessee and the A... ... ...
2022 (3) TMI 1635 - ITAT DELHI The SC partially allowed the appeal in a transfer pricing dispute. The Tribunal upheld TPO's exclusion of certain comparable companies due to financial year and functional dissimilarities. It directed the AO to grant foreign tax credit and MAT credit, finding penalty proceedings premature. The key ruling clarified that receivables should not be automatically treated as separate international transactions if already factored into working capital adjustments.
2017 (10) TMI 1384 - ITAT PUNE Curtailment of deduction claimed under section 10A - Deduction claimed u/s 10A by invoking the provisions of section 10A(7) r.w.s. 80IA(10) - assessee was providing high end Design Engineering Services to its associated enterprises and was being remunerated on Man Hourly rate basis, which has been computed applying the CUP methodology - Held that:- The assessee in its Engineering Design Development Services which was STPI unit shown net profit margin of 68.02%. The international transactions und... ... ...
2014 (3) TMI 891 - ITAT MUMBAI Transfer pricing adjustments - Selection of comparable - Whether a company performing KPO functions should be considered as comparable or not – providing back office support services to their overseas associated enterprises - Held that:- all the entities providing IT enabled services can be taken as potential comparables by applying a broad functionality test - further dissection or classification of ITES services can be done depending on the facts and circumstances of each case so as to select ... ... ...
2012 (11) TMI 132 - ITAT, BANGALORE Deduction u/s. 10A of the Income Tax Act - 100% EOU – application against the order of rectification of mistake u/s 154 passed by CIT(A) - Held that:- Whether the assessee is eligible for deduction u/s. 10A involves examination of facts, business activity carried on and the relevant provisions of the Act. It is a matter which requires a long drawn out process of reasoning or examining arguments on points where there may conceivably be two opinions or views - issue as to whether the assessee is i... ... ...
2022 (8) TMI 1412 - ITAT BANGALORE TDS u/s 195 - Disallowance of legal and professional fees made u/s 40(a)(i) - HELD THAT:- In order to bring the impugned payments within the Article 12 of India- USA DTAA, the services should have been made available technical knowledge etc to the assessee herein. In the instant case, the assessee has only availed professional services of non-residents in connection with tax compliances and the technical knowledge has not been made available . Since the make available clause fails, the impugned ... ... ...
Central Board of Direct Taxes specifies the various Information Technology enabled products or services u/s 80HHE The Central Board of Direct Taxes, under the authority of the Income-tax Act, 1961, specifies Information Technology enabled products or services eligible under sections 10A, 10B, and 80HHE. The specified services include back-office operations, call centers, content development or animation, data processing, engineering and design, geographic information system services, human resource services, insurance claim processing, legal databases, medical transcription, payroll, remote maintenance, revenue accounting, support centers, and website services. This notification aims to clarify eligible IT services for tax purposes.
2024 (2) TMI 101 - ITAT MUMBAI The SC/Tribunal addressed multiple taxation issues for a financial institution. Key outcomes include: allowing MTM losses, permitting bad debt write-offs, directing re-examination of re-possessed asset losses, and rejecting transfer pricing adjustments. The tribunal largely favored the assessee, providing nuanced interpretations across various tax provisions while remitting several matters for fresh assessment by the AO.
2023 (7) TMI 897 - ITAT BANGALORE TP adjustment - comparable selection - exclusion of UPS Print Systems Ltd. and BNR Udyog Ltd. from the list of comparables for the purpose of determining the ALP of the international transactions - HELD THAT:- Actually the AO issued a notice u/s 133(6) of the Act to M/s. Universal Print Systems Ltd. and no reply has been received from them. Having no option, he considered this company as comparable to the assessee company and included in the lists of comparables. In our opinion, the required inf... ... ...
2023 (4) TMI 520 - ITAT BANGALORE TP Adjustment - adjustment of arm s length price on the service rendered - main grievance of the assessee is that the TPO considered the assessee as ITeS company whereas the assessee is only a human resource provider - HELD THAT:- The segment applicable to the assessee for TP benchmarking is Placement services , recruitment services etc as done by the assessee in the TP documentation. In fact, the assessee requested the TPO to do a search on Recruitment, Placement services segment which is the m... ... ...
2020 (11) TMI 1057 - ITAT BANGALORE Taxability of Education cess - As submitted that, education cess is not tax and hence is not disallowable - HELD THAT:- As rely on the judgment of Hon ble Rajasthan High Court in the case of Chambal Fertilizers and Chemicals Ltd. v. Jt. CIT [ 2018 (10) TMI 589 - RAJASTHAN HIGH COURT ], which after taking into account aforementioned CBDT circular held that section 40(a)(ii) applies only to taxes and not to education cess - we allow the additional ground raised by assessee TP Adjustment - comparab... ... ...
2019 (5) TMI 737 - ITAT DELHI Determination of the ALP - ITeS services - selection of comparable - HELD THAT:- Looking to the functions performed by the Accentia technology and the various kinds of advanced assets in the form of software etcetera utilized, it is apparent that functionally the above company is not comparable with the assessee company. Hence we direct the learned transfer pricing officer /learned AO to exclude the above company from the comparability analysis. Infosys BPO Ltd - board of directors in that meeti... ... ...
TPA - ALP determination - AO/TPO directed to adopt CUP method for the medical transcription services and TNMM for the software development services - AT
2015 (3) TMI 151 - ITAT PUNE Deduction u/s.10B denied - the approval granted by the Software Technology Park of India (STPI) to the Bopodi unit of the Appellant is not ratified by the Board of Approval constituted u/s.14 of the Industrial Development Regulation Act - alternate claim of deduction u/s.10A rejected on the ground that the assessee has not claimed the deduction u/s.10A, through filing of return of income and has not furnished the prescribed report of the auditor at the time of filing of the return of income - He... ... ...
2014 (4) TMI 738 - ITAT HYDERABAD Entitlement of deduction u/s 10A of the Act - Production and development of computer software solutions – Held that:- As per the agreement, the assessee has to provide services at the place assigned by the Seavus Group and that the payment is to be made as per man-hours spent by the professionals - it is not possible to hold that the assessee has not exported any article or thing or computer software - the meaning of computer programme has been expanded as "computer program" "process" or "manage... ... ...
FREQUENTLY ASKED QUESTIONS ON SERVICE TAX AND THEIR ANSWERS This circular provides detailed information on service tax, addressing frequently asked questions regarding its nature, applicability, registration, payment, filing of returns, and specific service-related issues. Service tax is an indirect tax levied on certain services under the Finance Act, 1994. The responsibilities of service providers, registration procedures, payment timelines, and penalties for non-compliance. It also discusses exemptions, input credit schemes, and procedures for filing appeals and claiming refunds. Additionally, it clarifies the tax implications for various services introduced in the 2003-04 tax net and addresses export-related service tax issues.
2020 (9) TMI 1 - ITAT DELHI TP Adjustment - comparable selection - TPO re-characterized the business of the assessee and held the assessee to be a KPO service provider - HELD THAT:- We do not agree with the act of re-characterization of the assessee to be a KPO by the TPO in view of the fact that Hon ble Delhi High Court in the case of Rampgreen Solutions P Ltd [ 2015 (8) TMI 931 - DELHI HIGH COURT] has observed that the expression knowledge process outsourcing indicates the involvement of domain knowledge in providing ITe... ... ...
2019 (6) TMI 588 - ITAT DELHI TP Adjustment - comparable selection - functional similarity - HELD THAT:- For the purpose of the comparability all factors are of paramount importance. Hence, before relying upon any judicial precedent for exclusion or inclusion one has to cross the threshold of rule 10 B (2) of IT Rules, to ensure that the conditions specified therein are similar as decided by the honourable court. In view of this, the argument of the learned authorised representative cannot be accepted at the threshold itself... ... ...
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