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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Rebate / Refund of duty paid on Export Goods - Recovery of alleged excess grant of rebate - As far as availability of rebate is concerned, the notification providing for rebate talks of “duty paid” rather than “duty payable” and as such a manufacturer-exporter has a choice to pay the duty as per the basic rate or after availing the partial exemption and rebate shall be granted on the “duty paid”. - AT
Rebate / Refund of duty paid on Export Goods - Recovery of alleged excess grant of rebate - As far as availability of rebate is concerned, the notification providing for rebate talks of “duty paid” rather than “duty payable” and as such a manufacturer-exporter has a choice to pay the duty as per the basic rate or after availing the partial exemption and rebate shall be granted on the “duty paid”. - AT
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