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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Imported e-rickshaw parts without motors and batteries did not acquire the essential character of complete electric tricycles for Rule 2(a) classification, because those components were necessary for self-propelled operation. The consignments were therefore only parts and not CKD vehicles, so the department's reclassification was unsustainable. On that basis, the challenge to dropping proceedings for the past Bills of Entry failed, while the live duty demand, confiscation, redemption fine and penalties were set aside; the investigation deposit was ordered to be released with applicable interest.
Imported e-rickshaw parts without motors and batteries did not acquire the essential character of complete electric tricycles for Rule 2(a) classification, because those components were necessary for self-propelled operation. The consignments were therefore only parts and not CKD vehicles, so the department's reclassification was unsustainable. On that basis, the challenge to dropping proceedings for the past Bills of Entry failed, while the live duty demand, confiscation, redemption fine and penalties were set aside; the investigation deposit was ordered to be released with applicable interest.
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