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...
Recovery of erroneous Refund with interest - The argument of the department that there was delay on the part of the respondent to furnish details with regard to modvat credit and therefore the delay has occurred due to the negligence on the part of the respondent is not tenable. If there was undue delay on the part of respondent, the department could have rejected the refund claim for this reason - the respondent is eligible for interest under Section 11BB - AT
Recovery of erroneous Refund with interest - The argument of the department that there was delay on the part of the respondent to furnish details with regard to modvat credit and therefore the delay has occurred due to the negligence on the part of the respondent is not tenable. If there was undue delay on the part of respondent, the department could have rejected the refund claim for this reason - the respondent is eligible for interest under Section 11BB - AT
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