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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The case involved a dispute over a refund claim u/s 11B of the Central Excise Act. The Appellate Tribunal held that the time limitation for filing the refund claim did not apply as the duty was paid under protest. The Tribunal also ruled that the refund claims were valid even though the assessment of bills of entry was not challenged. The Revenue's argument that the refund claims were not maintainable without challenging the assessment was rejected. The Tribunal dismissed the Revenue's appeals, finding no merit in their arguments.
The case involved a dispute over a refund claim u/s 11B of the Central Excise Act. The Appellate Tribunal held that the time limitation for filing the refund claim did not apply as the duty was paid under protest. The Tribunal also ruled that the refund claims were valid even though the assessment of bills of entry was not challenged. The Revenue's argument that the refund claims were not maintainable without challenging the assessment was rejected. The Tribunal dismissed the Revenue's appeals, finding no merit in their arguments.
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