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 - levy of redemption fine and penalty - mis-classification of imported goods - The suo motu offer for making necessary rectification in the Bill of Entry was made before the Department pointed out or issue of any notice to the appellant. Thus, this is a case of simple clerical error and there is no case of contumacious conduct on the part of the appellant. - Confiscation and penalty both under Section 112(a)(ii) and 114AA of the Act set aside - AT
Confiscation - levy of redemption fine and penalty - mis-classification of imported goods - The suo motu offer for making necessary rectification in the Bill of Entry was made before the Department pointed out or issue of any notice to the appellant. Thus, this is a case of simple clerical error and there is no case of contumacious conduct on the part of the appellant. - Confiscation and penalty both under Section 112(a)(ii) and 114AA of the Act set aside - AT
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