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 of imported goods - In the facts and circumstances of this case there is failure on the part of the customs officer, by not following the laid down Customs procedure, particularly procedure of assessment as laid down. They have orally denied to pass an order of provisional assessment and have further used undue influence and have practically compelled the respondent importer to agree to dictates and agree for enhancement of the declared value, trying to giving total go by to the provisions of Section 17(4) read with 17(5) of the Act. - The respondent importer is entitled to consequential benefit - AT
Valuation of imported goods - In the facts and circumstances of this case there is failure on the part of the customs officer, by not following the laid down Customs procedure, particularly procedure of assessment as laid down. They have orally denied to pass an order of provisional assessment and have further used undue influence and have practically compelled the respondent importer to agree to dictates and agree for enhancement of the declared value, trying to giving total go by to the provisions of Section 17(4) read with 17(5) of the Act. - The respondent importer is entitled to consequential benefit - AT
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