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 - enhancement is made on the basis of DRI alert with reference to some NIDB data - at the time of hearing that Revenue has not served the copy of relevant material, it wanted to use against the respondent – importer, for enhancement in the transaction value. - Thus the respondent / importer had no opportunity to meet the allegations of Revenue, for finalisation of the proposed enhancement made at the time of provisional assessment, even at the finalisation stage of the same. - The respondent–importer shall be entitled to consequential benefits, in accordance of law. - AT
Valuation of imported goods - enhancement is made on the basis of DRI alert with reference to some NIDB data - at the time of hearing that Revenue has not served the copy of relevant material, it wanted to use against the respondent – importer, for enhancement in the transaction value. - Thus the respondent / importer had no opportunity to meet the allegations of Revenue, for finalisation of the proposed enhancement made at the time of provisional assessment, even at the finalisation stage of the same. - The respondent–importer shall be entitled to consequential benefits, in accordance of law. - AT
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