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 held that the appellant was ineligible for area-based exemption under N/N. 50/2003-CE. The Tribunal determined that M/s Stanley Controls was non-operational at the time of transfer, despite contrary claims. Evidence showed the transferor filed multiple quarterly returns on a single date just before takeover, reported inconsistent production figures, and showed nil production after transfer. The appellant failed to provide documentary evidence contradicting the finding that the transferor was defunct. CESTAT concluded that a facade of taking over a working unit was created solely to avail exemption benefits, emphasizing that CBEC Circular permits transfer of functioning units, not merely exemption entitlements. The demand for duty, interest, and penalties was upheld.
CESTAT held that the appellant was ineligible for area-based exemption under N/N. 50/2003-CE. The Tribunal determined that M/s Stanley Controls was non-operational at the time of transfer, despite contrary claims. Evidence showed the transferor filed multiple quarterly returns on a single date just before takeover, reported inconsistent production figures, and showed nil production after transfer. The appellant failed to provide documentary evidence contradicting the finding that the transferor was defunct. CESTAT concluded that a facade of taking over a working unit was created solely to avail exemption benefits, emphasizing that CBEC Circular permits transfer of functioning units, not merely exemption entitlements. The demand for duty, interest, and penalties was upheld.
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