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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100% EOU - refund of cenvat credit accumulated - The order of the lower authority has denied the refund stating that the waste generated is more than the prescribed norms. The above ground cannot be a reason for denial of refund of such accumulated credit. If excess waste was generated, the same has also been cleared in DTA on payment of duty due on such waste. This automatically will take care of such accumulated credit. - AT
100% EOU - refund of cenvat credit accumulated - The order of the lower authority has denied the refund stating that the waste generated is more than the prescribed norms. The above ground cannot be a reason for denial of refund of such accumulated credit. If excess waste was generated, the same has also been cleared in DTA on payment of duty due on such waste. This automatically will take care of such accumulated credit. - AT
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