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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Remission of duty - molasses lost during storage - It is not disputed that the loss is within the prescribed limit of 2%. Rule 21 does not lay down any procedure for giving information within 24 hours. Therefore, the substantive benefit cannot be denied in the statute by prescribing time limit of 24 hours, which is not laid down in law. - AT
Remission of duty - molasses lost during storage - It is not disputed that the loss is within the prescribed limit of 2%. Rule 21 does not lay down any procedure for giving information within 24 hours. Therefore, the substantive benefit cannot be denied in the statute by prescribing time limit of 24 hours, which is not laid down in law. - AT
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