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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Classification of goods - Ujala Supreme - ‘synthetic organic colouring matter’ or not - The only corollary that can be drawn from the use of HSN code is to have reference of the product viz-a-viz Customs Tariff Act, 1975 for the purposes of identification. Since the AVP is referable to item denoted by HSN code 3204 as adopted by Customs Tariff Act, 1975, the same can not be ignored for the purposes of H.P. VAT Act. - HC
Classification of goods - Ujala Supreme - ‘synthetic organic colouring matter’ or not - The only corollary that can be drawn from the use of HSN code is to have reference of the product viz-a-viz Customs Tariff Act, 1975 for the purposes of identification. Since the AVP is referable to item denoted by HSN code 3204 as adopted by Customs Tariff Act, 1975, the same can not be ignored for the purposes of H.P. VAT Act. - HC
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