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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Exemption from Customs Duty as per South Asia Free Trade Agreement (SAFTA) - The denial of the exemption certificate for the entire quantity of goods when the bulk of the goods are already covered by the SAFTA Certificate is not supported by any legal provision. Therefore the demands need to be set aside. The amount of redemption fine imposed by the impugned order as well as the penalties imposed upon the Appellants need to be proportionately reduced. - AT
Exemption from Customs Duty as per South Asia Free Trade Agreement (SAFTA) - The denial of the exemption certificate for the entire quantity of goods when the bulk of the goods are already covered by the SAFTA Certificate is not supported by any legal provision. Therefore the demands need to be set aside. The amount of redemption fine imposed by the impugned order as well as the penalties imposed upon the Appellants need to be proportionately reduced. - AT
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