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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Refund claim of Cenvat credit for input services used in export was contested on realization of export proceeds; the article explains that payment received in Indian rupees from a foreign bank account through authorised banking channels (including Vostro accounts) constitutes deemed repatriation of realized foreign exchange and may be evidenced by a Foreign Inward Remittance Certificate. Applying the tribunal ratio cited, the condition for export realisation is satisfied and orders denying the refund were set aside, with consequential reliefs as per law.
Refund claim of Cenvat credit for input services used in export was contested on realization of export proceeds; the article explains that payment received in Indian rupees from a foreign bank account through authorised banking channels (including Vostro accounts) constitutes deemed repatriation of realized foreign exchange and may be evidenced by a Foreign Inward Remittance Certificate. Applying the tribunal ratio cited, the condition for export realisation is satisfied and orders denying the refund were set aside, with consequential reliefs as per law.
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