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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Rejection of rebate claim - In the case in hand, it is not in dispute that the goods were exported by sea and the bills of lading are dated 03.06.2004 and 18.06.2004. Hence, any date prior to that cannot be taken as the date of export of goods. - The plea of estoppel is also merely to be noticed and rejected for the reason that there cannot be estoppel against statute. Once Section 11-B of the Act clearly defines when the goods are treated to be exported. - HC
Rejection of rebate claim - In the case in hand, it is not in dispute that the goods were exported by sea and the bills of lading are dated 03.06.2004 and 18.06.2004. Hence, any date prior to that cannot be taken as the date of export of goods. - The plea of estoppel is also merely to be noticed and rejected for the reason that there cannot be estoppel against statute. Once Section 11-B of the Act clearly defines when the goods are treated to be exported. - HC
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