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...
SSI Exemption - use of brand name of others - There is no ambiguity in the wordings of the Notification. Therefore, there are no reason for the appellants to entertain any doubts regarding the notification. The appellant’s submission that they had a bona fide belief that goods attracted NIL rate of duty was same as non-excisable goods. There is no merit in the argument. - it can only be concluded that the appellants have suppressed material facts from the Department. In such circumstances, the extended period is rightly invokable. - AT
SSI Exemption - use of brand name of others - There is no ambiguity in the wordings of the Notification. Therefore, there are no reason for the appellants to entertain any doubts regarding the notification. The appellant’s submission that they had a bona fide belief that goods attracted NIL rate of duty was same as non-excisable goods. There is no merit in the argument. - it can only be concluded that the appellants have suppressed material facts from the Department. In such circumstances, the extended period is rightly invokable. - AT
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