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 Customs Duty - duty paid under protest - rejection on the ground that the transfer bonds in which the goods were transferred from Vizag Customs to EOU Bheemli have been closed which was duly intimated to the appellant but was not contested at the appropriate stage - The provision makes it clear that Procedure for submission of transfer bonds and the closure thereof is not possible in the absence of the executor of the bonds who requests removal of the imported goods from one warehouse to another. - This is not a fit case for refund - AT
Refund of Customs Duty - duty paid under protest - rejection on the ground that the transfer bonds in which the goods were transferred from Vizag Customs to EOU Bheemli have been closed which was duly intimated to the appellant but was not contested at the appropriate stage - The provision makes it clear that Procedure for submission of transfer bonds and the closure thereof is not possible in the absence of the executor of the bonds who requests removal of the imported goods from one warehouse to another. - This is not a fit case for refund - AT
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