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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Non-fulfilment of export obligation - we do not find any merit in the contention of the appellant that CVD should not be demanded from them because they would be eligible to avail the Modvat credit from CVD. If that view is accepted, then no importer-manufacturer would ever be required to pay CVD on the ground that Cenvat Credit of the same would be availed by them at the next stage. - AT
Non-fulfilment of export obligation - we do not find any merit in the contention of the appellant that CVD should not be demanded from them because they would be eligible to avail the Modvat credit from CVD. If that view is accepted, then no importer-manufacturer would ever be required to pay CVD on the ground that Cenvat Credit of the same would be availed by them at the next stage. - AT
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