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 - Fake documents without actual receipts of the inputs against such documents - The Tribunal found the department's reliance on uncorroborated assumptions to be insufficient for denying Cenvat credit. The appellant had accounted for the inputs in their records, and the payments were made through proper channels, negating the department's assumptions.
Wrongful availment of CENVAT Credit - Fake documents without actual receipts of the inputs against such documents - The Tribunal found the department's reliance on uncorroborated assumptions to be insufficient for denying Cenvat credit. The appellant had accounted for the inputs in their records, and the payments were made through proper channels, negating the department's assumptions.
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