Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Coal beneficiation through wet process is discussed as yielding a commercially improved output and, on the authorities cited, may fall within manufacture or production for purposes of cost records and cost audit under the Companies (Cost Records and Audit) Rules, 2014. The text notes that manufacture requires a transformation into a new and different article with a distinctive name, character and use, but whether a particular beneficiation process retains the original character of coal or is only processing depends on the actual facts and evidence, making the defence a mixed question of fact and law.
Coal beneficiation through wet process is discussed as yielding a commercially improved output and, on the authorities cited, may fall within manufacture or production for purposes of cost records and cost audit under the Companies (Cost Records and Audit) Rules, 2014. The text notes that manufacture requires a transformation into a new and different article with a distinctive name, character and use, but whether a particular beneficiation process retains the original character of coal or is only processing depends on the actual facts and evidence, making the defence a mixed question of fact and law.
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