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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Refund of SAD - relevant Time period - the board also issued a circular no. 23/2010-Cus wherein, it was clarified that one year should be taken from the date of actual payment irrespective whether it is provisional assessment or final assessment. However, the Hon’ble High Court dealing with the very same circular since concluded that one year should be counted from the date of the final assessment, the said circular was held ultravires and quashed. - The limitation of one year has to be reckoned from the date of finalization of Bill of entry. - AT
Refund of SAD - relevant Time period - the board also issued a circular no. 23/2010-Cus wherein, it was clarified that one year should be taken from the date of actual payment irrespective whether it is provisional assessment or final assessment. However, the Hon’ble High Court dealing with the very same circular since concluded that one year should be counted from the date of the final assessment, the said circular was held ultravires and quashed. - The limitation of one year has to be reckoned from the date of finalization of Bill of entry. - AT
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