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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Violation of policy conditions - import of used car - prohibited or restricted goods or not - The car which was imported, the importation of the same was not prohibited. It is not the case of the revenue that there was any prohibition insofar as the importation of the car was concerned at any point of time and admittedly, the only violation, if at all, was the non-usage of the said car for a period of one year abroad, before importation. That ipso facto cannot make the car liable for absolute confiscation - AT
Violation of policy conditions - import of used car - prohibited or restricted goods or not - The car which was imported, the importation of the same was not prohibited. It is not the case of the revenue that there was any prohibition insofar as the importation of the car was concerned at any point of time and admittedly, the only violation, if at all, was the non-usage of the said car for a period of one year abroad, before importation. That ipso facto cannot make the car liable for absolute confiscation - AT
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