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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Reversal of CENVAT Credit - inputs consumed/utilized for production, at the work-in-progress stage, were destroyed in fire in the factory - The Tribunal examined the legal provisions and found that destroyed WIP or semi-finished goods should not be considered as inputs subject to duty reversal. Therefore, they allowed the appeal and ruled in favor of the appellant, clarifying that no duty reversal was required on the destroyed inputs forming part of WIP/semi-finished goods.
Reversal of CENVAT Credit - inputs consumed/utilized for production, at the work-in-progress stage, were destroyed in fire in the factory - The Tribunal examined the legal provisions and found that destroyed WIP or semi-finished goods should not be considered as inputs subject to duty reversal. Therefore, they allowed the appeal and ruled in favor of the appellant, clarifying that no duty reversal was required on the destroyed inputs forming part of WIP/semi-finished goods.
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