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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CENVAT Credit - Assuming that no credit has been taken for the activities not amounting to manufacture then there was no scope for payment of any Central Excise Duty on removal of final product. However, since the final product has suffered duty, reversal of credit taken by the Respondent on the inputs will not result in any loss of Revenue to the Government exchequer - AT
CENVAT Credit - Assuming that no credit has been taken for the activities not amounting to manufacture then there was no scope for payment of any Central Excise Duty on removal of final product. However, since the final product has suffered duty, reversal of credit taken by the Respondent on the inputs will not result in any loss of Revenue to the Government exchequer - AT
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