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 - related party transaction - rejection of declared value - failure of the appellant to submit evidence of identical/contemporary imports - the loading has been applied uniformly without reference either to the base price of each article of import or of the total value of the consignment in each bill of entry. - In the absence of re-assessed bills of entry, we have before us, at best, a piece-meal determination which, being premature, would be inappropriate to dispose off. - AT
Valuation of imported goods - related party transaction - rejection of declared value - failure of the appellant to submit evidence of identical/contemporary imports - the loading has been applied uniformly without reference either to the base price of each article of import or of the total value of the consignment in each bill of entry. - In the absence of re-assessed bills of entry, we have before us, at best, a piece-meal determination which, being premature, would be inappropriate to dispose off. - AT
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