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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Pre-deposit by making reversal of CENVAT credit with interest -The mandatory pre-deposit made by the appellant in terms of Section 35F of the Central Excise Act was required to be refunded by the Department to the appellant and the said amount was not refunded. - The impugned order rejecting the refund claim under Section 11B on limitation is not sustainable in law
Pre-deposit by making reversal of CENVAT credit with interest -The mandatory pre-deposit made by the appellant in terms of Section 35F of the Central Excise Act was required to be refunded by the Department to the appellant and the said amount was not refunded. - The impugned order rejecting the refund claim under Section 11B on limitation is not sustainable in law
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