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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In the matters of classification, it is the commercial parlance test which is relevant. It is test which has and that has to be adopted by the assessing officer. He has to decide as to how the product is treated in the market by the men of commerce in the trade. It is not the clarification or a particular view of the superior officer which should weigh his mind though such clarifications in the matters of classifications may be a relevant factor.
In the matters of classification, it is the commercial parlance test which is relevant. It is test which has and that has to be adopted by the assessing officer. He has to decide as to how the product is treated in the market by the men of commerce in the trade. It is not the clarification or a particular view of the superior officer which should weigh his mind though such clarifications in the matters of classifications may be a relevant factor.
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