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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Smuggling (illicit import) or goods of domestic origin - Betel Nuts - Seizure and confiscation of goods - The goods can be used, sold, re-sold etc. without any duty either on the importer or any subsequent buyer of such goods to keep or produce the import documents. Of course, if the goods have been smuggled into India, not through the designated Customs Ports, Airports or Land Customs Station, they will be liable for confiscation, but it must be established that the goods have been so imported - The Department has not proved in this case that the goods were smuggled goods. - Order set aside - AT
Smuggling (illicit import) or goods of domestic origin - Betel Nuts - Seizure and confiscation of goods - The goods can be used, sold, re-sold etc. without any duty either on the importer or any subsequent buyer of such goods to keep or produce the import documents. Of course, if the goods have been smuggled into India, not through the designated Customs Ports, Airports or Land Customs Station, they will be liable for confiscation, but it must be established that the goods have been so imported - The Department has not proved in this case that the goods were smuggled goods. - Order set aside - AT
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