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...
Voluntary statements made by an importer, its proprietor and its agents during a Customs Act inquiry may be relied on as substantive admissions where they acknowledge under-invoicing and retail sale price misdeclaration. Denial of cross-examination does not breach natural justice where those persons cannot be compelled to depose against themselves. Original supplier invoices recovered from the importer's laptop and forensically examined in its presence constitute primary electronic evidence, without requiring a certificate applicable to secondary electronic records. Evidence of misdeclaration justified rejection of the declared transaction value and sequential redetermination under the Customs Valuation Rules. The consequential duty demand, confiscation and penalties were sustained.
Voluntary statements made by an importer, its proprietor and its agents during a Customs Act inquiry may be relied on as substantive admissions where they acknowledge under-invoicing and retail sale price misdeclaration. Denial of cross-examination does not breach natural justice where those persons cannot be compelled to depose against themselves. Original supplier invoices recovered from the importer's laptop and forensically examined in its presence constitute primary electronic evidence, without requiring a certificate applicable to secondary electronic records. Evidence of misdeclaration justified rejection of the declared transaction value and sequential redetermination under the Customs Valuation Rules. The consequential duty demand, confiscation and penalties were sustained.
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