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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Rejection of the request for amendment in the bills of lading - Existence of two bills of lading - The confiscation of the impugned goods having been, thus, accepted, section 126 of Customs Act, 1962 vests such goods with the Central Government. Therefore, notwithstanding any commercial engagement of the appellant herein with any other person in relation to the goods, this ownership by the Central Government cannot be alienated. - Request cannot be accepted - AT
Rejection of the request for amendment in the bills of lading - Existence of two bills of lading - The confiscation of the impugned goods having been, thus, accepted, section 126 of Customs Act, 1962 vests such goods with the Central Government. Therefore, notwithstanding any commercial engagement of the appellant herein with any other person in relation to the goods, this ownership by the Central Government cannot be alienated. - Request cannot be accepted - AT
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