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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penalties u/s 112(a)/114AA of the Customs Act - duty free import of the raw Lead Ingots for manufacturing diverted to local market - goods were transported from ICD, Loni to Kathua via New Delhi with proper documents issued by the transporters - no investigation to transporters, no other evidence, even the revenue is not disputing export of lead alloys by appellant - Admittedly, lead alloys cannot be manufactured from Vacuum - demand not sustainable
penalties u/s 112(a)/114AA of the Customs Act - duty free import of the raw Lead Ingots for manufacturing diverted to local market - goods were transported from ICD, Loni to Kathua via New Delhi with proper documents issued by the transporters - no investigation to transporters, no other evidence, even the revenue is not disputing export of lead alloys by appellant - Admittedly, lead alloys cannot be manufactured from Vacuum - demand not sustainable
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