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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Interest on demands made by the appellant during investigation - any deposits made if have not been confirmed as duty the time bar of Section 11B of Central Excise Act cannot be invoked. It stands clear that the amount in question was not the amount of duty after the Tribunal set aside the duty liability of the appellant. Hence, it is held that section 11 B is not applicable to such deposits. - AT
Interest on demands made by the appellant during investigation - any deposits made if have not been confirmed as duty the time bar of Section 11B of Central Excise Act cannot be invoked. It stands clear that the amount in question was not the amount of duty after the Tribunal set aside the duty liability of the appellant. Hence, it is held that section 11 B is not applicable to such deposits. - AT
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