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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Imposition of penalty under Rule 26 (2) of CER - availment of irregular CENVAT Credit - invoices without actual receipt of inputs - Though the opting of SVLDRS should not have any bearing on the other cases who are contesting before this Tribunal but it shows that the other party to whom Invoices were supplied has accepted the demand of fraudulent Cenvat Credit. - The appellant is liable for penalty under Rule 26 (2) for wrongly passing of the credit - AT
Imposition of penalty under Rule 26 (2) of CER - availment of irregular CENVAT Credit - invoices without actual receipt of inputs - Though the opting of SVLDRS should not have any bearing on the other cases who are contesting before this Tribunal but it shows that the other party to whom Invoices were supplied has accepted the demand of fraudulent Cenvat Credit. - The appellant is liable for penalty under Rule 26 (2) for wrongly passing of the credit - AT
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