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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CESTAT examined service tax recovery with interest and penalties concerning insurance commission, finance payouts, and MUL incentives. The appellant had already paid demanded amounts prior to Show Cause Notice issuance. Following High Court remand directions, CESTAT confirmed the admitted demands and appropriated payments accordingly. Since payments were made before Show Cause Notice, penalties were deemed unwarranted for confirmed demands. The Tribunal maintained its earlier decision of setting aside remaining demands and penalties. The matter originated from handling charges, repair services, and expense reimbursements under reverse charge mechanism. Appeal disposed of with confirmation of pre-paid demands but elimination of associated penalties.
CESTAT examined service tax recovery with interest and penalties concerning insurance commission, finance payouts, and MUL incentives. The appellant had already paid demanded amounts prior to Show Cause Notice issuance. Following High Court remand directions, CESTAT confirmed the admitted demands and appropriated payments accordingly. Since payments were made before Show Cause Notice, penalties were deemed unwarranted for confirmed demands. The Tribunal maintained its earlier decision of setting aside remaining demands and penalties. The matter originated from handling charges, repair services, and expense reimbursements under reverse charge mechanism. Appeal disposed of with confirmation of pre-paid demands but elimination of associated penalties.
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