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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Wrongful availment of CENVAT Credit - input services - broadcasting agencies - the agreements entered with the broadcasting agencies were not on behalf of WWIL, but on its own behalf by the appellant. Further, perusal of the invoices issued by the broadcasting agencies to the appellant on which the appellant has paid the service tax gives him a right to claim the cenvat credit on input services. - Credit allowed - AT
Wrongful availment of CENVAT Credit - input services - broadcasting agencies - the agreements entered with the broadcasting agencies were not on behalf of WWIL, but on its own behalf by the appellant. Further, perusal of the invoices issued by the broadcasting agencies to the appellant on which the appellant has paid the service tax gives him a right to claim the cenvat credit on input services. - Credit allowed - AT
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