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...
Excise assessment of superior kerosene oil is determined by its form and exemption eligibility at factory removal. Kerosene cleared for sale through the Public Distribution System after satisfying exemption conditions does not become assessable at motor-spirit or high-speed-diesel rates merely because it later forms a pipeline interface beyond the refinery; an administrative circular cannot create liability contrary to governing provisions. The differential-duty demand on interface kerosene was therefore unsustainable. Extended limitation requires evidence of suppression or wilful misstatement with intent to evade duty; departmental ability to inquire and a bona fide belief defeated its use. Without such evidence, penalties against the entities and employee were not imposable.
Excise assessment of superior kerosene oil is determined by its form and exemption eligibility at factory removal. Kerosene cleared for sale through the Public Distribution System after satisfying exemption conditions does not become assessable at motor-spirit or high-speed-diesel rates merely because it later forms a pipeline interface beyond the refinery; an administrative circular cannot create liability contrary to governing provisions. The differential-duty demand on interface kerosene was therefore unsustainable. Extended limitation requires evidence of suppression or wilful misstatement with intent to evade duty; departmental ability to inquire and a bona fide belief defeated its use. Without such evidence, penalties against the entities and employee were not imposable.
Note: It is a system-generated summary and is for quick reference only.