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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
