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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Supporting manufacturer or not - Procurement of inputs under Advance licence Scheme - suppression of facts or Mis-declaration - The appellant vide letter 25.02.2010 again intimated that there is no violation of Para 4.16 of Handbook Procedure. From the above it is clear that the appellant have disclosed all the information as regard procurement of material under advance authorization from M/s Sterlite Industries (I) Ltd. Therefore, there is no suppression of facts or Mis-declaration on the part of the appellant. - The demand is clearly hit by limitations. - AT
Supporting manufacturer or not - Procurement of inputs under Advance licence Scheme - suppression of facts or Mis-declaration - The appellant vide letter 25.02.2010 again intimated that there is no violation of Para 4.16 of Handbook Procedure. From the above it is clear that the appellant have disclosed all the information as regard procurement of material under advance authorization from M/s Sterlite Industries (I) Ltd. Therefore, there is no suppression of facts or Mis-declaration on the part of the appellant. - The demand is clearly hit by limitations. - AT
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