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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Benefit Exemption from duty - imported goods “Skin Barriers Micropore Surgical Tapes” or not - This Tribunal being a creature of statute cannot sit in judgment on interpretation of a notification or the purport of the notification. However, the Bench is not Writ Court to decide the property of the notification being creature of the statute. This Bench has no jurisdiction to interpret the intention of the notification. - The arguments of the appellants are not acceptable and it is held that the exemption is not available to them. - AT
Benefit Exemption from duty - imported goods “Skin Barriers Micropore Surgical Tapes” or not - This Tribunal being a creature of statute cannot sit in judgment on interpretation of a notification or the purport of the notification. However, the Bench is not Writ Court to decide the property of the notification being creature of the statute. This Bench has no jurisdiction to interpret the intention of the notification. - The arguments of the appellants are not acceptable and it is held that the exemption is not available to them. - AT
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