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 service tax paid - rejection on the ground of failure to cross the bar of unjust enrichment - It is difficult to understand from where he borrowed this inference that ultimate incidence of all taxes shifts from business to the consumer and mere reflection of the same in the books of account (perhaps he meant thereby receivable) does not reflect actual shifting of incidence. No prudent man would concur to his finding that is based on erroneous understanding of simple English sentence available in the Encyclopaedia Britannica strangely he equated “most of the cost of tax” with “all taxes”. - Refund to be given - AT
Refund of service tax paid - rejection on the ground of failure to cross the bar of unjust enrichment - It is difficult to understand from where he borrowed this inference that ultimate incidence of all taxes shifts from business to the consumer and mere reflection of the same in the books of account (perhaps he meant thereby receivable) does not reflect actual shifting of incidence. No prudent man would concur to his finding that is based on erroneous understanding of simple English sentence available in the Encyclopaedia Britannica strangely he equated “most of the cost of tax” with “all taxes”. - Refund to be given - AT
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