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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
CENVAT Credit availed by the Appellant for providing the output service of ‘renting of immovable property’ - there is no manner of doubt that CENVAT Credit availed by the appellant on inputs, inputs services and capital goods service used for construction of the Mall, which was ultimately let out could not have been denied to the appellant. - Further, even though the period in dispute may be from 1 April, 2011 to 31 March, 2012, but the ‘input services’ were received by the appellant prior to 1 April, 2011. - Credit allowed.
CENVAT Credit availed by the Appellant for providing the output service of ‘renting of immovable property’ - there is no manner of doubt that CENVAT Credit availed by the appellant on inputs, inputs services and capital goods service used for construction of the Mall, which was ultimately let out could not have been denied to the appellant. - Further, even though the period in dispute may be from 1 April, 2011 to 31 March, 2012, but the ‘input services’ were received by the appellant prior to 1 April, 2011. - Credit allowed.
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