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...
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Conditional customs duty exemption for an imported aircraft requires use solely for authorised non-scheduled charter services. Commercial operation without the required regulatory approval breaches the post-import exemption condition, making the aircraft liable to confiscation, redemption fine, consequential customs duty and penalties on the importer and responsible managing personnel. Duty following redemption of confiscated goods arises as a consequence of confiscation proceedings rather than as a non-levy or short-levy demand, so the limitation framework for such demands does not apply. Where actual freight and transit-insurance costs are available, customs valuation must use those costs rather than notional additions; duty requires recomputation on that basis.
Conditional customs duty exemption for an imported aircraft requires use solely for authorised non-scheduled charter services. Commercial operation without the required regulatory approval breaches the post-import exemption condition, making the aircraft liable to confiscation, redemption fine, consequential customs duty and penalties on the importer and responsible managing personnel. Duty following redemption of confiscated goods arises as a consequence of confiscation proceedings rather than as a non-levy or short-levy demand, so the limitation framework for such demands does not apply. Where actual freight and transit-insurance costs are available, customs valuation must use those costs rather than notional additions; duty requires recomputation on that basis.
Note: It is a system-generated summary and is for quick reference only.