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 dismissed the appeal regarding interest entitlement on pre-deposit under Section 35FF of Central Excise Act, 1944. The tribunal held that the appellant is not entitled to interest from the date of deposit until refund, but may receive interest as prescribed under Sections 11BB or 35FF. The decision relied on precedential rulings, specifically the Division Bench's interpretation in a prior case involving similar pre-deposit interest claims. The tribunal rejected the appellant's contention of interest calculation from deposit date, affirming strict adherence to statutory provisions governing pre-deposit interest calculations.
CESTAT dismissed the appeal regarding interest entitlement on pre-deposit under Section 35FF of Central Excise Act, 1944. The tribunal held that the appellant is not entitled to interest from the date of deposit until refund, but may receive interest as prescribed under Sections 11BB or 35FF. The decision relied on precedential rulings, specifically the Division Bench's interpretation in a prior case involving similar pre-deposit interest claims. The tribunal rejected the appellant's contention of interest calculation from deposit date, affirming strict adherence to statutory provisions governing pre-deposit interest calculations.
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