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 - time limitation - entitlement for Credit beyond six month - since the time limit has been extended from six months to one year by substitution in the Notification No.21/2014-CE (N.T.) dated 11.07.2014, the time limit shall be taken as one year and as per the submission of learned counsel, the invoices issued after the date of notification dated 11.07.2014 credit was taken within one year. - AT
CENVAT Credit - time limitation - entitlement for Credit beyond six month - since the time limit has been extended from six months to one year by substitution in the Notification No.21/2014-CE (N.T.) dated 11.07.2014, the time limit shall be taken as one year and as per the submission of learned counsel, the invoices issued after the date of notification dated 11.07.2014 credit was taken within one year. - AT
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