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...
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100% EOU - import of second hand machinery - even though the goods have not been cleared for home consumption, the same have not been accounted for to the satisfaction of the proper officer inasmuch as the condition under which such warehousing was permitted was not satisfied - the Customs authorities have rightly demanded the Customs duty on the goods which have been found uninstalled and unused - AT
100% EOU - import of second hand machinery - even though the goods have not been cleared for home consumption, the same have not been accounted for to the satisfaction of the proper officer inasmuch as the condition under which such warehousing was permitted was not satisfied - the Customs authorities have rightly demanded the Customs duty on the goods which have been found uninstalled and unused - AT
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