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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Movement of imported goods for gamma irradiation was permitted under a case-specific customs-controlled procedure, with the goods remaining under customs control and movement for treatment not amounting to clearance under the Customs Act. Transport, treatment, supervision, testing, sealing, insurance and indemnity were left entirely at the importer's sole risk and responsibility, and the process had to be completed within the time fixed by the Court. The arrangement was expressly confined to the facts of the matter and was not to be treated as precedent. The High Court's classification decision was affirmed, but the underlying question of law was left open for decision in an appropriate case.
Movement of imported goods for gamma irradiation was permitted under a case-specific customs-controlled procedure, with the goods remaining under customs control and movement for treatment not amounting to clearance under the Customs Act. Transport, treatment, supervision, testing, sealing, insurance and indemnity were left entirely at the importer's sole risk and responsibility, and the process had to be completed within the time fixed by the Court. The arrangement was expressly confined to the facts of the matter and was not to be treated as precedent. The High Court's classification decision was affirmed, but the underlying question of law was left open for decision in an appropriate case.
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