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 - Credit availed during the month of December, 2016 on the basis of invoices which were more than one year old from the date of purchase of inputs - bare perusal of Rule 3 Sub Rule (2) of Cenvat Credit Rules 2004 makes it clear that the appellant was entitled to claim Cenvat Credit with respect to the inputs contained in the final products lying in the stock on the date when the goods manufactured becomes excisable. In the present case the appellants goods post being manufactured in December, 2016 became excisable in December 2016 itself. Hence, the availment of credit on the inputs of such manufactured goods was very much available to the appellant. - AT
CENVAT Credit - Credit availed during the month of December, 2016 on the basis of invoices which were more than one year old from the date of purchase of inputs - bare perusal of Rule 3 Sub Rule (2) of Cenvat Credit Rules 2004 makes it clear that the appellant was entitled to claim Cenvat Credit with respect to the inputs contained in the final products lying in the stock on the date when the goods manufactured becomes excisable. In the present case the appellants goods post being manufactured in December, 2016 became excisable in December 2016 itself. Hence, the availment of credit on the inputs of such manufactured goods was very much available to the appellant. - AT
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