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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Export of job-worked goods to the overseas supplier, who had supplied the imported goods to the job worker in India - benefit of N/N. 32/97-Cus - No job work activity was done since the contract was cancelled - at the time of issuance of show-cause notice, the subject goods were not available in India and that at the time of importation of the subject goods, the conditions of the Notification were duly complied with. - Demand set aside - AT
Export of job-worked goods to the overseas supplier, who had supplied the imported goods to the job worker in India - benefit of N/N. 32/97-Cus - No job work activity was done since the contract was cancelled - at the time of issuance of show-cause notice, the subject goods were not available in India and that at the time of importation of the subject goods, the conditions of the Notification were duly complied with. - Demand set aside - AT
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