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 - The Foreign Trade Act and the Section 125 of the Customs Act does not make any bar from redemption of such restricted goods imported without authorization on payment of duty on retail market value and there is distinction between what is prohibited and what is restricted. In those circumstances, the goods cannot be held absolutely confiscated or cannot be restricted for clearance for home consumption, hence, the imported goods are allowed to be cleared for home consumption on payment of redemption fine and penalty. - AT
Valuation of imported goods - The Foreign Trade Act and the Section 125 of the Customs Act does not make any bar from redemption of such restricted goods imported without authorization on payment of duty on retail market value and there is distinction between what is prohibited and what is restricted. In those circumstances, the goods cannot be held absolutely confiscated or cannot be restricted for clearance for home consumption, hence, the imported goods are allowed to be cleared for home consumption on payment of redemption fine and penalty. - AT
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