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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Liability of interest - Since differential duty was voluntarily paid before finalization of assessments which did not result in any dues and payable to the Govt, the interest was not leviable. If the interest was payable on the duty on which the assessee paid differential duty prior to finalization of assessment, then the Central Excise rules 2002 would have specifically said so - AT
Liability of interest - Since differential duty was voluntarily paid before finalization of assessments which did not result in any dues and payable to the Govt, the interest was not leviable. If the interest was payable on the duty on which the assessee paid differential duty prior to finalization of assessment, then the Central Excise rules 2002 would have specifically said so - AT
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