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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CENVAT Credit - generation of electricity which, later on, is cleared to its sister unit - The Appellate Tribunal finds that the appellant is indeed entitled to Cenvat Credit on inputs and input services used for the production of electricity, which is transferred to its sister unit at Urse free of cost. The Tribunal emphasizes that since the electricity is transferred free of cost, the valuation should not be based on the price of electricity sold by other entities. The Tribunal relies on precedent and distinguishes the case from situations where electricity is sold for a price outside the factory.
CENVAT Credit - generation of electricity which, later on, is cleared to its sister unit - The Appellate Tribunal finds that the appellant is indeed entitled to Cenvat Credit on inputs and input services used for the production of electricity, which is transferred to its sister unit at Urse free of cost. The Tribunal emphasizes that since the electricity is transferred free of cost, the valuation should not be based on the price of electricity sold by other entities. The Tribunal relies on precedent and distinguishes the case from situations where electricity is sold for a price outside the factory.
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