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 - input services - tour packages provided to dealers - nexus with sales promotion or not - it was possible for the appellant to pay in cash expenses for tour. Instead they have provided them tour packages. Therefore, the said tour packages can be considered as dealer’s commission. Therefore, Cenvat credit of service tax paid on tour packages are admissible as Cenvat credit in the present case. - AT
CENVAT Credit - input services - tour packages provided to dealers - nexus with sales promotion or not - it was possible for the appellant to pay in cash expenses for tour. Instead they have provided them tour packages. Therefore, the said tour packages can be considered as dealer’s commission. Therefore, Cenvat credit of service tax paid on tour packages are admissible as Cenvat credit in the present case. - AT
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