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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CENVAT Credit - input services - Outward transportation of Hazardous Waste - In fact this activity is though the way of transportation but it is the disposal of Hazardous waste which is generating during the course of manufacture. In this fact the service of transportation is covered under the main clause of dentition provided under Rule 2(l) of Cenvat Credit Rules, 2004. Therefore, the judgment of ultratech of the Apex Court is not at all relevant in the facts of the present case. - AT
CENVAT Credit - input services - Outward transportation of Hazardous Waste - In fact this activity is though the way of transportation but it is the disposal of Hazardous waste which is generating during the course of manufacture. In this fact the service of transportation is covered under the main clause of dentition provided under Rule 2(l) of Cenvat Credit Rules, 2004. Therefore, the judgment of ultratech of the Apex Court is not at all relevant in the facts of the present case. - AT
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