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...
Tariff classification of imported mixed lots of polyester knitted fabrics requires evidence of the actual composition of goods covered by each Bill of Entry. A description as "polyester knitted fabric" does not, without testing or other cogent evidence, establish the characteristics needed to reclassify mixed assorted fabrics as fabrics of synthetic fibres. The declared classification under CTH 6006 9000 remained applicable, and the proposed classification under CTH 6006 3200, with differential duty and interest, was unsustainable. Penalty for misclassification also required proof of deliberate suppression, wilful misstatement, or intent to evade duty; an interpretational classification dispute did not establish those elements.
Tariff classification of imported mixed lots of polyester knitted fabrics requires evidence of the actual composition of goods covered by each Bill of Entry. A description as "polyester knitted fabric" does not, without testing or other cogent evidence, establish the characteristics needed to reclassify mixed assorted fabrics as fabrics of synthetic fibres. The declared classification under CTH 6006 9000 remained applicable, and the proposed classification under CTH 6006 3200, with differential duty and interest, was unsustainable. Penalty for misclassification also required proof of deliberate suppression, wilful misstatement, or intent to evade duty; an interpretational classification dispute did not establish those elements.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
