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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The Tribunal treated the dispute as covered by its earlier coordinate Bench ruling on similar facts involving alleged misuse of duty-free import authorisations and discharge of export obligations. Applying that precedent, it found no case for imposing penalties on the supporting manufacturer or the deemed export recipient under customs law, and upheld the order to the extent it had declined such penalties. The Revenue's challenge to non-imposition of penalties therefore failed.
The Tribunal treated the dispute as covered by its earlier coordinate Bench ruling on similar facts involving alleged misuse of duty-free import authorisations and discharge of export obligations. Applying that precedent, it found no case for imposing penalties on the supporting manufacturer or the deemed export recipient under customs law, and upheld the order to the extent it had declined such penalties. The Revenue's challenge to non-imposition of penalties therefore failed.
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