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 - Once the credit is availed, the use of such credit is governed by Rule 3 of the Cenvat Credit Rules, 2004. Sub-Rule (4) of the said Rule stipulates that Cenvat credit may be utilized for payment of any duty of excise on any final product. Here there is no one to one co-relation or condition that credit on input services can be utilized only for discharging tax on output services or Excise Duty on final products cannot be paid using Cenvat credit availed on input services - AT
Cenvat credit - Once the credit is availed, the use of such credit is governed by Rule 3 of the Cenvat Credit Rules, 2004. Sub-Rule (4) of the said Rule stipulates that Cenvat credit may be utilized for payment of any duty of excise on any final product. Here there is no one to one co-relation or condition that credit on input services can be utilized only for discharging tax on output services or Excise Duty on final products cannot be paid using Cenvat credit availed on input services - AT
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