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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SSI Exemption - value of clearances - clubbing of clearances - The tribunal found the appellants engaged in the manufacture and sale of excisable goods without Central Excise registration, crossing the exemption turnover limit but still claiming benefits under the SSI exemption notification. The appellants created a separate entity to continue availing of the SSI exemption, which was deemed a scheme for suppressing the value of clearances to evade duty. The tribunal upheld the demand for Central Excise duty for the period from April 2013 to November 2014, including the appropriation of a deposit made during the investigation towards this duty liability.
SSI Exemption - value of clearances - clubbing of clearances - The tribunal found the appellants engaged in the manufacture and sale of excisable goods without Central Excise registration, crossing the exemption turnover limit but still claiming benefits under the SSI exemption notification. The appellants created a separate entity to continue availing of the SSI exemption, which was deemed a scheme for suppressing the value of clearances to evade duty. The tribunal upheld the demand for Central Excise duty for the period from April 2013 to November 2014, including the appropriation of a deposit made during the investigation towards this duty liability.
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