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 - exported of inputs as such - even if inputs are assumed to have been cleared as such, they are duty paid excisable goods which were cleared under bond in terms of Notification issued under Rule 19 which does not provide for reversal of credit of duty paid on such exported excisable goods because legislative intent was to promote export of goods and not export of taxes. - AT
CENVAT Credit - exported of inputs as such - even if inputs are assumed to have been cleared as such, they are duty paid excisable goods which were cleared under bond in terms of Notification issued under Rule 19 which does not provide for reversal of credit of duty paid on such exported excisable goods because legislative intent was to promote export of goods and not export of taxes. - AT
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