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/inputs or not - M.S. Plates, M.S. Channels, H.R. Coils, M.S. Angles etc. - no manner of doubt that respondent-assessee is entitled to Cenvat Credit in respect of items used as structural support for capital goods prior to the amendment of Explanation 2 to Rule 2 (k) by notification dated 7.7.2009 - amendment is applicable only prospectively
CENVAT Credit - capital goods/inputs or not - M.S. Plates, M.S. Channels, H.R. Coils, M.S. Angles etc. - no manner of doubt that respondent-assessee is entitled to Cenvat Credit in respect of items used as structural support for capital goods prior to the amendment of Explanation 2 to Rule 2 (k) by notification dated 7.7.2009 - amendment is applicable only prospectively
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