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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Confiscation of goods - prohibited/restricted goods or not - import of consignment of Sajji Khar - It is a settled law that any condition is imposed on the import shall not apply to the import already originated from the port of shipping - In the present case also the instruction dated 21.05.2020 was issued much after not only the import of goods but also after filing of warehousing Bill of entry. It is also undisputed fact that the same product i.e. Sajji Khar has been allowed to be imported without the condition as imposed by the department in the present case on the earlier occasions by various importers. - The goods are not liable for confiscation - AT
Confiscation of goods - prohibited/restricted goods or not - import of consignment of Sajji Khar - It is a settled law that any condition is imposed on the import shall not apply to the import already originated from the port of shipping - In the present case also the instruction dated 21.05.2020 was issued much after not only the import of goods but also after filing of warehousing Bill of entry. It is also undisputed fact that the same product i.e. Sajji Khar has been allowed to be imported without the condition as imposed by the department in the present case on the earlier occasions by various importers. - The goods are not liable for confiscation - AT
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