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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Refund of CENVAT Credit - clearances under CT1 Certificates for export - There is no provision in the definition of turnover of services that the export turnover should be taken as per the date of invoice. The refund has to be computed by taking date of FIRC during the particular quarter for the purpose of export turnover. - The denial of refund of CENVAT Credit as time-barred is not acceptable - AT
Refund of CENVAT Credit - clearances under CT1 Certificates for export - There is no provision in the definition of turnover of services that the export turnover should be taken as per the date of invoice. The refund has to be computed by taking date of FIRC during the particular quarter for the purpose of export turnover. - The denial of refund of CENVAT Credit as time-barred is not acceptable - AT
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