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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Customs valuation under Rule 12 treats declared transaction value as the primary basis, and it may be rejected only on objective, reasonable doubt supported by contemporaneous comparables or proof of additional consideration. If rejection is justified, valuation must then proceed strictly through the prescribed sequential rules, not by arbitrary standard rates. Electronic records in customs adjudication require authenticity, certification and a clear chain of custody, while denial of cross-examination and non-supply of relied-upon material undermine natural justice. Extended limitation requires strict proof of suppression or intent to evade duty, and confiscation or penalty cannot rest on a mere valuation dispute or unproven misdeclaration.
Customs valuation under Rule 12 treats declared transaction value as the primary basis, and it may be rejected only on objective, reasonable doubt supported by contemporaneous comparables or proof of additional consideration. If rejection is justified, valuation must then proceed strictly through the prescribed sequential rules, not by arbitrary standard rates. Electronic records in customs adjudication require authenticity, certification and a clear chain of custody, while denial of cross-examination and non-supply of relied-upon material undermine natural justice. Extended limitation requires strict proof of suppression or intent to evade duty, and confiscation or penalty cannot rest on a mere valuation dispute or unproven misdeclaration.
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