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 - Input Service Distributors - credit denied by the Department on the ground that after the amendment to the definition of ‘input service’ w.e.f. 01.03.2001 in section 2(l) of the CENVAT Credit Rules, 2004, the appellant was not entitled to avail CENVAT Credit on such services - Invocation of the extended period of limitation - the issue relating to invocation of the extended period of limitation has been dealt with by the Commissioner in a very cryptic manner, though a detailed reply had been filed by the appellant. - AT
CENVAT Credit - Input Service Distributors - credit denied by the Department on the ground that after the amendment to the definition of ‘input service’ w.e.f. 01.03.2001 in section 2(l) of the CENVAT Credit Rules, 2004, the appellant was not entitled to avail CENVAT Credit on such services - Invocation of the extended period of limitation - the issue relating to invocation of the extended period of limitation has been dealt with by the Commissioner in a very cryptic manner, though a detailed reply had been filed by the appellant. - AT
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