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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Jurisdiction of HC u/s 130 of the Customs Act, 1962 - We are of the opinion that the question raised in this appeal does not have any connection with the rate of duty. Whether the notification was applied from the date of its publication by the DGFT or from the date of its publication by the customs under Section 25[4] of the said Act the rate of duty remained the same. The only controversy is the date from which that rate of duty was applicable. If that is the question, this court has the jurisdiction to hear this appeal. - HC
Jurisdiction of HC u/s 130 of the Customs Act, 1962 - We are of the opinion that the question raised in this appeal does not have any connection with the rate of duty. Whether the notification was applied from the date of its publication by the DGFT or from the date of its publication by the customs under Section 25[4] of the said Act the rate of duty remained the same. The only controversy is the date from which that rate of duty was applicable. If that is the question, this court has the jurisdiction to hear this appeal. - HC
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