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 regarding availing CENVAT credit for construction services used in building housing units for staff. The tribunal held that the construction services were directly related to the manufacturing activity as they ensured smooth operation and security of the plant. The tribunal interpreted the rules broadly to include services not directly linked to manufacturing. Regarding time limitation and suppression of facts, it was held that the appellant had regularly disclosed all relevant details, thus no suppression was found. The lower authority's decision was overturned, and the appeal was allowed by the CESTAT.
The case involved a dispute regarding availing CENVAT credit for construction services used in building housing units for staff. The tribunal held that the construction services were directly related to the manufacturing activity as they ensured smooth operation and security of the plant. The tribunal interpreted the rules broadly to include services not directly linked to manufacturing. Regarding time limitation and suppression of facts, it was held that the appellant had regularly disclosed all relevant details, thus no suppression was found. The lower authority's decision was overturned, and the appeal was allowed by the CESTAT.
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