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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Extended period of limitation - manufacture - Revenue had issued Service Tax registration to the appellant for the activity of galvanization and therefore the activity undertaken by the appellant was known to the department from the date of issue of said registration under Service Tax and that the show cause notice dated 02.04.2012 was issued for the period from 2007-08 - SCN is clearly hit by limitation - AT
Extended period of limitation - manufacture - Revenue had issued Service Tax registration to the appellant for the activity of galvanization and therefore the activity undertaken by the appellant was known to the department from the date of issue of said registration under Service Tax and that the show cause notice dated 02.04.2012 was issued for the period from 2007-08 - SCN is clearly hit by limitation - AT
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