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 unutilized CENVAT credit accumulated - Once it is established that the Appellants are providing output service they are entitled to take credit of input service. It is an admitted fact that credit proportionate to services provided within the taxable territory has been reversed. After such reversal remaining unutilized CENVAT Credit pertains only to export of legal services and becomes eligible for refund in terms of Rule 5 of CCR and Notification no. 27/2012-CE(NT) - AT
Refund of unutilized CENVAT credit accumulated - Once it is established that the Appellants are providing output service they are entitled to take credit of input service. It is an admitted fact that credit proportionate to services provided within the taxable territory has been reversed. After such reversal remaining unutilized CENVAT Credit pertains only to export of legal services and becomes eligible for refund in terms of Rule 5 of CCR and Notification no. 27/2012-CE(NT) - AT
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