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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Appellant established eligibility for input tax credit on various services utilized in manufacturing final products. Tribunal held that when jurisdictional authorities did not dispute credit availed by input service distribution centers, department cannot deny credit at manufacturing unit on vague allegations without specific objections. Tribunal relied on its previous order allowing credit for similar services. Outdoor catering and civil works services availed prior to 2011 were for repair, maintenance, and modernization, not factory setup. All services qualified as eligible input services, and credit denial based on vague allegations at manufacturing unit without challenging input service distributor's credit was improper. Impugned order set aside, appeal allowed.
Appellant established eligibility for input tax credit on various services utilized in manufacturing final products. Tribunal held that when jurisdictional authorities did not dispute credit availed by input service distribution centers, department cannot deny credit at manufacturing unit on vague allegations without specific objections. Tribunal relied on its previous order allowing credit for similar services. Outdoor catering and civil works services availed prior to 2011 were for repair, maintenance, and modernization, not factory setup. All services qualified as eligible input services, and credit denial based on vague allegations at manufacturing unit without challenging input service distributor's credit was improper. Impugned order set aside, appeal allowed.
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