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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Recovery of service tax with interest and penalty - entitlement to the benefit of the VCES Scheme -Despite directions from the Commissioner (Appeals) to produce necessary documents, the appellant failed to comply, which undermined their case. - The tribunal observed that the burden of proof is on the appellant to substantiate their claims, particularly regarding VCES compliance, exemption under the threshold limit, and classification of services. - Despite the appellant's non-compliance, the court, in the interest of justice, grants another opportunity for the appellant to produce relevant documents in support of their submissions.
Recovery of service tax with interest and penalty - entitlement to the benefit of the VCES Scheme -Despite directions from the Commissioner (Appeals) to produce necessary documents, the appellant failed to comply, which undermined their case. - The tribunal observed that the burden of proof is on the appellant to substantiate their claims, particularly regarding VCES compliance, exemption under the threshold limit, and classification of services. - Despite the appellant's non-compliance, the court, in the interest of justice, grants another opportunity for the appellant to produce relevant documents in support of their submissions.
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