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 - Capital Goods - The contention of the Revenue that they are huge machines and cannot be removed from one premises to other premises is not born out by any evidence whereas the appellant has produced the delivery challan for transfer of the machineries from the main premises to the job-worker premises and it is returned to the main factory. - credit allowed.
CENVAT Credit - Capital Goods - The contention of the Revenue that they are huge machines and cannot be removed from one premises to other premises is not born out by any evidence whereas the appellant has produced the delivery challan for transfer of the machineries from the main premises to the job-worker premises and it is returned to the main factory. - credit allowed.
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