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 involves a dispute u/s CENVAT Credit Rules. The Appellate Tribunal addressed issues related to Scope of Show Cause Notice (SCN), reversal of CENVAT Credit, and time limitation. Tribunal held that including services beyond the scope of SCN is impermissible. Appellant's reversal of CENVAT Credit on a proportionate basis was found unsupported by law. Amendment to Rule 6 clarified recovery of only proportionate credit. Extended limitation period demand was rejected due to lack of evidence of suppression. The appeal was allowed on both merit and limitation grounds.
The case involves a dispute u/s CENVAT Credit Rules. The Appellate Tribunal addressed issues related to Scope of Show Cause Notice (SCN), reversal of CENVAT Credit, and time limitation. Tribunal held that including services beyond the scope of SCN is impermissible. Appellant's reversal of CENVAT Credit on a proportionate basis was found unsupported by law. Amendment to Rule 6 clarified recovery of only proportionate credit. Extended limitation period demand was rejected due to lack of evidence of suppression. The appeal was allowed on both merit and limitation grounds.
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