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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Revocation of Courier License - The appellant Courier was mandated to work within legal framework of the Customs Act, 1962, Rules and Regulations made thereunder. The appellant failed to do so. The appellant did not exercise due diligence in submitting the correct and complete information to the assessing officer with reference to the impugned goods. By violating the Regulations, it had given scope for massive misuse of the facility given in addition to loss of Revenue. - the revocation of License is justified and any leniency shown in the misconduct of this nature would send wrong signals. - AT
Revocation of Courier License - The appellant Courier was mandated to work within legal framework of the Customs Act, 1962, Rules and Regulations made thereunder. The appellant failed to do so. The appellant did not exercise due diligence in submitting the correct and complete information to the assessing officer with reference to the impugned goods. By violating the Regulations, it had given scope for massive misuse of the facility given in addition to loss of Revenue. - the revocation of License is justified and any leniency shown in the misconduct of this nature would send wrong signals. - AT
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