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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Eligibility of refund claim of input services on export of goods - The contention of the appellant that cleaning activity is not taxable and therefore refund of Service Tax paid thereon should be given under Section 11B of Central Excise Act is not relevant and tenable because the refund claim was filed and claimed in terms of provisions of Notification No. 41/2007-ST and not under the provisions of Section 11B of Central Excise Act - AT
Eligibility of refund claim of input services on export of goods - The contention of the appellant that cleaning activity is not taxable and therefore refund of Service Tax paid thereon should be given under Section 11B of Central Excise Act is not relevant and tenable because the refund claim was filed and claimed in terms of provisions of Notification No. 41/2007-ST and not under the provisions of Section 11B of Central Excise Act - AT
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