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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Input tax Credit - Coal is a raw material for manufacturing of cement or not - in the present case, the coal used in the process of manufacture of cement is indeed an input within the meaning of Section 2(25) of the OET Act and therefore qualifies for input tax credit as claimed by the Petitioner - the Tribunal erred in holding that the coal is not a raw material for manufacturing cement - the Tribunal erred in coming to the conclusion that coal could not be treated as a raw material vis-à-vis the finished product i.e. cement - HC
Input tax Credit - Coal is a raw material for manufacturing of cement or not - in the present case, the coal used in the process of manufacture of cement is indeed an input within the meaning of Section 2(25) of the OET Act and therefore qualifies for input tax credit as claimed by the Petitioner - the Tribunal erred in holding that the coal is not a raw material for manufacturing cement - the Tribunal erred in coming to the conclusion that coal could not be treated as a raw material vis-à-vis the finished product i.e. cement - HC
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