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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Classification of imported consignment - two-sided coated paper in rolls - one-sided coated paper in rolls - the petitioner has classified the goods in question under eight digit ITC (HS) 4810 13 90. If the respondents are asked to classify the goods in question, they cannot come up with a different classification. Yet by introducing an impermissible yardstick namely, GSM variation, the respondents have arrived at a finding that the imported goods constitute a stock lot. This is patently illegal. - HC
Classification of imported consignment - two-sided coated paper in rolls - one-sided coated paper in rolls - the petitioner has classified the goods in question under eight digit ITC (HS) 4810 13 90. If the respondents are asked to classify the goods in question, they cannot come up with a different classification. Yet by introducing an impermissible yardstick namely, GSM variation, the respondents have arrived at a finding that the imported goods constitute a stock lot. This is patently illegal. - HC
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