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...
Refund of Customs duty - principle of unjust enrichment - as per Certificate issued by the CA in favour of the respondent/Assessee to the effect that the amount of refund due has not been taken into account while arriving at the cost of services provided to the customers and therefore, the incidence of duty in question has never been passed on to the customers - refund will not result in any unjust enrichment - duly allowable
Refund of Customs duty - principle of unjust enrichment - as per Certificate issued by the CA in favour of the respondent/Assessee to the effect that the amount of refund due has not been taken into account while arriving at the cost of services provided to the customers and therefore, the incidence of duty in question has never been passed on to the customers - refund will not result in any unjust enrichment - duly allowable
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