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 is eligible for Cenvat credit in three key aspects: (1) outward transportation to franchisee outlets as place of removal, (2) sales commission paid to franchisees for product marketing, and (3) commercial rent for retail outlets. The tribunal determined that services related to goods movement, sales promotion, and storage up to the point of removal are integral to manufacturing process. The input service credits were consequently allowed, recognizing the broader interpretation of input services under Cenvat Credit Rules, 2004. The appeal was ultimately allowed in favor of the appellant, affirming the eligibility of input service credits across multiple service categories.
CESTAT held that the appellant is eligible for Cenvat credit in three key aspects: (1) outward transportation to franchisee outlets as place of removal, (2) sales commission paid to franchisees for product marketing, and (3) commercial rent for retail outlets. The tribunal determined that services related to goods movement, sales promotion, and storage up to the point of removal are integral to manufacturing process. The input service credits were consequently allowed, recognizing the broader interpretation of input services under Cenvat Credit Rules, 2004. The appeal was ultimately allowed in favor of the appellant, affirming the eligibility of input service credits across multiple service categories.
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