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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Import of seismic research vessel with consumable stores - As there is no dispute that the appellant has obtained the Essentiality Certificate issued by Director General of Hydrocarbons that the said goods have been used in connection with the petroleum operations, therefore, relying on the decision in the case of CGG Marine, it is held that the respondent is entitled for the benefit of exemption N/N. 21/2002. - AT
Import of seismic research vessel with consumable stores - As there is no dispute that the appellant has obtained the Essentiality Certificate issued by Director General of Hydrocarbons that the said goods have been used in connection with the petroleum operations, therefore, relying on the decision in the case of CGG Marine, it is held that the respondent is entitled for the benefit of exemption N/N. 21/2002. - AT
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