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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Claim of benefit of exemption - re-imported air craft engines and parts thereof which were exported for the purposes of repairs/ reconditioning etc. - It is very clear that additional duty, integrated tax, compensation cess are exempted and customs duty would be limited to be taxed on the value of the fair cost of repairs carried out including cost of materials used in repairs, insurance and freight charges. - AT
Claim of benefit of exemption - re-imported air craft engines and parts thereof which were exported for the purposes of repairs/ reconditioning etc. - It is very clear that additional duty, integrated tax, compensation cess are exempted and customs duty would be limited to be taxed on the value of the fair cost of repairs carried out including cost of materials used in repairs, insurance and freight charges. - AT
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