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...
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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 Appellate Tribunal upheld the order that the interstate transfer of goods by the appellant from its factory in Coimbatore to its depot in Palakkad, Kerala, during the period from 01.04.1996 to 28.08.1996, constituted inter-state sales, attracting central sales tax. The finding was based on the correspondence and invoices indicating that sales occasioned the inter-state movement of goods under the disputed Forms F during that period. For the remaining assessment year, the order of assessment was set aside. The appellant's alternative prayer for an order u/s 22(1B) of the CST Act, directing Kerala to transfer the refundable amount paid as sales tax to Tamil Nadu, could not be granted due to lack of details regarding the sales tax claimed to have been paid in Kerala. Consequently, the appeal was dismissed.
The Appellate Tribunal upheld the order that the interstate transfer of goods by the appellant from its factory in Coimbatore to its depot in Palakkad, Kerala, during the period from 01.04.1996 to 28.08.1996, constituted inter-state sales, attracting central sales tax. The finding was based on the correspondence and invoices indicating that sales occasioned the inter-state movement of goods under the disputed Forms F during that period. For the remaining assessment year, the order of assessment was set aside. The appellant's alternative prayer for an order u/s 22(1B) of the CST Act, directing Kerala to transfer the refundable amount paid as sales tax to Tamil Nadu, could not be granted due to lack of details regarding the sales tax claimed to have been paid in Kerala. Consequently, the appeal was dismissed.
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