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 eligibility of Cenvat Credit on input services used beyond the place of removal. The Appellant failed to provide proper evidence supporting their case. They are directed to present all details and evidence to the Adjudicating Authority to establish eligibility. For input services used in manufacturing, Appellant as a service provider can claim credit. Job work services require maintaining ST-3 Returns to show Cenvat Credit. Nexus must be established for cross-utilization. Input tax credit is not available for outward GTA services by Job Worker as a manufacturer. Adjudicating Authority must ensure natural justice by allowing Appellant to present arguments and evidence. Proceedings to be completed within three months from the date of order.
The case involves eligibility of Cenvat Credit on input services used beyond the place of removal. The Appellant failed to provide proper evidence supporting their case. They are directed to present all details and evidence to the Adjudicating Authority to establish eligibility. For input services used in manufacturing, Appellant as a service provider can claim credit. Job work services require maintaining ST-3 Returns to show Cenvat Credit. Nexus must be established for cross-utilization. Input tax credit is not available for outward GTA services by Job Worker as a manufacturer. Adjudicating Authority must ensure natural justice by allowing Appellant to present arguments and evidence. Proceedings to be completed within three months from the date of order.
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