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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SEZ Unit - Refund of accumulated CENVAT of input service - rejection on the ground that since the amount of service tax on which CENVAT credit was availed was paid under VCES Scheme, in terms of Section 109 of Finance Act, 2013, any amount paid in pursuance of declaration made under sub section 1 of section 107 was not refundable under any circumstances - Restriction in applicable in case of SEZ unit - refund allowed.
SEZ Unit - Refund of accumulated CENVAT of input service - rejection on the ground that since the amount of service tax on which CENVAT credit was availed was paid under VCES Scheme, in terms of Section 109 of Finance Act, 2013, any amount paid in pursuance of declaration made under sub section 1 of section 107 was not refundable under any circumstances - Restriction in applicable in case of SEZ unit - refund allowed.
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