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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Benefit of exemption country of origin certificates - As per the documents submitted by the appellant it appears that there is no doubt on the authenticity of the country of origin certificate issued and signed by Mr. Rumaiti. However, to clear any doubt it is the burden on the department to get the verification from the Indonesian Government regarding authenticity of Certificate of origin which has not been discharged by the department. Therefore, in the interest of justice, one chance is given to the department to get the verification from concerned authorities about the genuineness of the certificate of origin issued by Mr.Rumaiti, thereafter to pass a fresh order. - AT
Benefit of exemption country of origin certificates - As per the documents submitted by the appellant it appears that there is no doubt on the authenticity of the country of origin certificate issued and signed by Mr. Rumaiti. However, to clear any doubt it is the burden on the department to get the verification from the Indonesian Government regarding authenticity of Certificate of origin which has not been discharged by the department. Therefore, in the interest of justice, one chance is given to the department to get the verification from concerned authorities about the genuineness of the certificate of origin issued by Mr.Rumaiti, thereafter to pass a fresh order. - AT
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