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 - inputs - goods which is used even not in the manufacture directly but even if it is used in relation to the manufacture and indirectly, the said goods qualify as inputs - Therefore, in the present case all the goods which are specialized goods used for storage and safety of the gold, these are considered to be inputs used in relation to the manufacture of the final product i.e. gold indirectly - credit allowed on all inputs. - AT
CENVAT Credit - inputs - goods which is used even not in the manufacture directly but even if it is used in relation to the manufacture and indirectly, the said goods qualify as inputs - Therefore, in the present case all the goods which are specialized goods used for storage and safety of the gold, these are considered to be inputs used in relation to the manufacture of the final product i.e. gold indirectly - credit allowed on all inputs. - AT
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