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 Services - services of electricity expenses in connection with their head office - The location of the head office is immaterial so long it is used only for the operation of the factory’s activities, therefore, any service received in head office is in relation to the manufacturing activity of the appellant. - even though the input service was received by the head office but since it is in connection with overall business activity of the manufacturing unit, the credit is admissible - AT
CENVAT Credit - Input Services - services of electricity expenses in connection with their head office - The location of the head office is immaterial so long it is used only for the operation of the factory’s activities, therefore, any service received in head office is in relation to the manufacturing activity of the appellant. - even though the input service was received by the head office but since it is in connection with overall business activity of the manufacturing unit, the credit is admissible - AT
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