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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Valuation - price variation clause - the price of finished goods is to be revised and duty is to be paid on higher price. In case the price of raw material falls, the appellant is entitled to claim less amount of the manufactured goods. Therefore, as per the said clause, as per price variation clause, the duty needs to be recalculated as per the amount received from the buyer towards supply of goods by the appellant. The same is required to be examined by the adjudicating authority. - AT
Valuation - price variation clause - the price of finished goods is to be revised and duty is to be paid on higher price. In case the price of raw material falls, the appellant is entitled to claim less amount of the manufactured goods. Therefore, as per the said clause, as per price variation clause, the duty needs to be recalculated as per the amount received from the buyer towards supply of goods by the appellant. The same is required to be examined by the adjudicating authority. - AT
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