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...
EPCG duty-exemption compliance is evidenced by installation certificates for the installation requirement and an Export Obligation Discharge Certificate for fulfilment of export obligations. Where the licensing authority issues the discharge certificate after adjudication because it was pending despite an application and supporting documents, subsequent customs acceptance of that certificate and cancellation of the related bonds confirms compliance with EPCG notification conditions. A duty demand, redemption fine and penalty based solely on earlier non-production of the certificate are inconsistent with that subsequent acceptance of compliance.
EPCG duty-exemption compliance is evidenced by installation certificates for the installation requirement and an Export Obligation Discharge Certificate for fulfilment of export obligations. Where the licensing authority issues the discharge certificate after adjudication because it was pending despite an application and supporting documents, subsequent customs acceptance of that certificate and cancellation of the related bonds confirms compliance with EPCG notification conditions. A duty demand, redemption fine and penalty based solely on earlier non-production of the certificate are inconsistent with that subsequent acceptance of compliance.
Note: It is a system-generated summary and is for quick reference only.
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