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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As per Rule 3 of the Cenvat Credit Rules 2004 whatever input / capital goods have been received by the respondent in their factory they are entitled to take Cenvat Credit, it is immaterial that whether the impugned goods attract duty or not, when there is no dispute that these goods have suffered duty. - AT
As per Rule 3 of the Cenvat Credit Rules 2004 whatever input / capital goods have been received by the respondent in their factory they are entitled to take Cenvat Credit, it is immaterial that whether the impugned goods attract duty or not, when there is no dispute that these goods have suffered duty. - AT
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