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 - Irrespective of the person whether it is service recipient or service provider is liable to pay the service tax but so long the service tax was admittedly paid even by the recipient of the service, the Cenvat credit cannot be denied. This issue is no longer res Integra as this tribunal in following judgments for categorically hold that even though the portion of the service tax which was supposed to be paid by the some other person, so long the service tax was paid, the credit of said service tax cannot be denied to the recipient of service. - AT
CENVAT Credit - input services - Irrespective of the person whether it is service recipient or service provider is liable to pay the service tax but so long the service tax was admittedly paid even by the recipient of the service, the Cenvat credit cannot be denied. This issue is no longer res Integra as this tribunal in following judgments for categorically hold that even though the portion of the service tax which was supposed to be paid by the some other person, so long the service tax was paid, the credit of said service tax cannot be denied to the recipient of service. - AT
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