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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Duty Drawback - Advance Licences for Duty-free import of goods - drawback for 50% of FOB value - The benefit of Section 75 ibid namely the drawback should be allowed of duties of Customs chargeable under Customs Act cannot be denied as the benefit of duty drawback is allowable on the imported goods used in the manufacture of goods which are exported. Revenue has nowhere disputed the fact of export made by the appellant. Hence, the impugned order is contrary and not in accordance with the scheme of the statutory provision as provided under Section 75 ibid - AT
Duty Drawback - Advance Licences for Duty-free import of goods - drawback for 50% of FOB value - The benefit of Section 75 ibid namely the drawback should be allowed of duties of Customs chargeable under Customs Act cannot be denied as the benefit of duty drawback is allowable on the imported goods used in the manufacture of goods which are exported. Revenue has nowhere disputed the fact of export made by the appellant. Hence, the impugned order is contrary and not in accordance with the scheme of the statutory provision as provided under Section 75 ibid - AT
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