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 - alleged fake documents - there is no evidence brought forth by the Department that there was no delivery of goods or that the invoices were bogus, except that statement of Shri Amit Gupta and transporters, but no cross examination of the witnesses was provided - Once it is demonstrated that reasonable steps had been taken as per Rules 9(3), to cast an impossible or impractical burden on the assessee is not permissible
CENVAT Credit - alleged fake documents - there is no evidence brought forth by the Department that there was no delivery of goods or that the invoices were bogus, except that statement of Shri Amit Gupta and transporters, but no cross examination of the witnesses was provided - Once it is demonstrated that reasonable steps had been taken as per Rules 9(3), to cast an impossible or impractical burden on the assessee is not permissible
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