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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Interest liability - seeking waiver of interest since the payment of service tax was paid under the amnesty scheme - The tribunal observed that the appellant's payment of service tax, even under an amnesty scheme, necessitated interest payment as a corollary. Therefore, the appellant's contention for exemption from interest payment was deemed untenable. Regarding the refund claim, the tribunal affirmed that the appellant's payment of service tax without contestation implied acceptance of the department's stance. Additionally, the tribunal reasoned that the amnesty scheme, under which the appellant paid the tax, did not absolve them from interest liability.
Interest liability - seeking waiver of interest since the payment of service tax was paid under the amnesty scheme - The tribunal observed that the appellant's payment of service tax, even under an amnesty scheme, necessitated interest payment as a corollary. Therefore, the appellant's contention for exemption from interest payment was deemed untenable. Regarding the refund claim, the tribunal affirmed that the appellant's payment of service tax without contestation implied acceptance of the department's stance. Additionally, the tribunal reasoned that the amnesty scheme, under which the appellant paid the tax, did not absolve them from interest liability.
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