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...
AIFTA Certificates of Origin may be rejected only through compliance with the domestic verification safeguards in Rules 7(c) and 7(d); suspected fraud does not remove those requirements under Rule 23. Delayed, partial verification and an unauthenticated foreign finding of non-authenticity, without origin test reports, signature evidence or authenticated underlying material, do not establish fraudulent origin or justify denial of preferential tariff treatment. Extended limitation for customs recovery requires proof of the importer's positive collusion, wilful misstatement or suppression, including conscious participation in certificate falsification. Non-culpatory statements and absent evidence of knowledge or fraud do not sustain duty, interest or penalties under the extended period.
AIFTA Certificates of Origin may be rejected only through compliance with the domestic verification safeguards in Rules 7(c) and 7(d); suspected fraud does not remove those requirements under Rule 23. Delayed, partial verification and an unauthenticated foreign finding of non-authenticity, without origin test reports, signature evidence or authenticated underlying material, do not establish fraudulent origin or justify denial of preferential tariff treatment. Extended limitation for customs recovery requires proof of the importer's positive collusion, wilful misstatement or suppression, including conscious participation in certificate falsification. Non-culpatory statements and absent evidence of knowledge or fraud do not sustain duty, interest or penalties under the extended period.
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