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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Rewards under the Merchandise Exports from India Scheme ('MEIS') - Seeking completion of process of sanctioning and grant of the reward - the petitioner had not intimated the intent for claiming MEIS benefits initially on their shipping bills dated 30.03.2015. There is so much of impact prevailing on the export being made from SEZ unit as it was from Kandla SEZ that the export has been made by the petitioner - there could be no exclusion of SEZ or non-EDI Port unit for availing the benefit. - HC
Rewards under the Merchandise Exports from India Scheme ('MEIS') - Seeking completion of process of sanctioning and grant of the reward - the petitioner had not intimated the intent for claiming MEIS benefits initially on their shipping bills dated 30.03.2015. There is so much of impact prevailing on the export being made from SEZ unit as it was from Kandla SEZ that the export has been made by the petitioner - there could be no exclusion of SEZ or non-EDI Port unit for availing the benefit. - HC
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