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...
Validity of second SCN - import of restricted item - The first order having being set aside by the Tribunal, on the ground that no specific contravention of the Act had been alleged or established against the appellant, it is difficult to see how the Revenue could sustain an entirely inconsistent order in respect of the second show cause notice.
Validity of second SCN - import of restricted item - The first order having being set aside by the Tribunal, on the ground that no specific contravention of the Act had been alleged or established against the appellant, it is difficult to see how the Revenue could sustain an entirely inconsistent order in respect of the second show cause notice.
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