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 ruled on a complex tax refund dispute, directing the Commissioner to refund Rs. 256.45 crores in cash within four weeks with applicable interest. The Tribunal invalidated a subsequent show-cause notice challenging the original order as legally null. Regarding another disputed amount of Rs. 122.05 crores, the Tribunal mandated a detailed document scrutiny by the department within three months to determine refund eligibility, requiring a compliance report by 10.06.2025. The decision emphasized adherence to the Tribunal's original order and proper legal procedures in tax credit and refund matters.
CESTAT ruled on a complex tax refund dispute, directing the Commissioner to refund Rs. 256.45 crores in cash within four weeks with applicable interest. The Tribunal invalidated a subsequent show-cause notice challenging the original order as legally null. Regarding another disputed amount of Rs. 122.05 crores, the Tribunal mandated a detailed document scrutiny by the department within three months to determine refund eligibility, requiring a compliance report by 10.06.2025. The decision emphasized adherence to the Tribunal's original order and proper legal procedures in tax credit and refund matters.
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