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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Clandestine removal demand based on electricity consumption not sustainable as mere electricity consumption cannot be the sole basis for determining duty liability. Demand based on ledger pages recovered from Director's briefcase and accepted by him confirmed. Demand based on documents recovered from Directors' residences and accepted by Director confirmed. Demand for risers and runners based on electricity consumption set aside. Demand for shortage in raw material set aside due to lack of evidence. Demand for inadmissible Cenvat credit on scrap receipt from sister concern set aside as alleged transactions were paper transactions only. Equivalent penalties set aside or confirmed accordingly.
Clandestine removal demand based on electricity consumption not sustainable as mere electricity consumption cannot be the sole basis for determining duty liability. Demand based on ledger pages recovered from Director's briefcase and accepted by him confirmed. Demand based on documents recovered from Directors' residences and accepted by Director confirmed. Demand for risers and runners based on electricity consumption set aside. Demand for shortage in raw material set aside due to lack of evidence. Demand for inadmissible Cenvat credit on scrap receipt from sister concern set aside as alleged transactions were paper transactions only. Equivalent penalties set aside or confirmed accordingly.
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