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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Revocation of custom broker license / CB License - The allegation that the appellant did not demonstrate the desired level of diligence and efficiency is too vague, and lacking in objectivity, for ascertainment without specificity. Moreover, neither the Inquiry Authority nor the Commissioner of Customs had taken it up on themselves to scrutinize the documentary and oral evidence for arriving at such a conclusion.
Revocation of custom broker license / CB License - The allegation that the appellant did not demonstrate the desired level of diligence and efficiency is too vague, and lacking in objectivity, for ascertainment without specificity. Moreover, neither the Inquiry Authority nor the Commissioner of Customs had taken it up on themselves to scrutinize the documentary and oral evidence for arriving at such a conclusion.
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