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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Refund of Customs Duty - Period of limitation - the order of this Tribunal dated 03.03.2011 was challenged by the Revenue before the Hon’ble High Court and before the decision of the Hon’ble High Court was delivered, the refund claim was filed by the appellant. In that circumstances, how can be said that the refund claim filed by the appellant is barred by limitation. In fact, the refund claim filed by the appellant before the limitation starts.
Refund of Customs Duty - Period of limitation - the order of this Tribunal dated 03.03.2011 was challenged by the Revenue before the Hon’ble High Court and before the decision of the Hon’ble High Court was delivered, the refund claim was filed by the appellant. In that circumstances, how can be said that the refund claim filed by the appellant is barred by limitation. In fact, the refund claim filed by the appellant before the limitation starts.
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