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 - Extended period of limitation - Technical Testing and Analysis - there is nothing found which can substantiate the allegation of the department about wilful suppression. Learned Counsel have taken me through various invoices during the period in issue, which have been placed on record. From the perusal of the said invoices also it is clear that the services were availed for the existing plant at Rajariyawas and not for any new or proposed plant. - Credit cannot be denied - AT
CENVAT Credit - Extended period of limitation - Technical Testing and Analysis - there is nothing found which can substantiate the allegation of the department about wilful suppression. Learned Counsel have taken me through various invoices during the period in issue, which have been placed on record. From the perusal of the said invoices also it is clear that the services were availed for the existing plant at Rajariyawas and not for any new or proposed plant. - Credit cannot be denied - AT
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