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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Valuation of imported goods - Brand New Azimut 68 Motor Yacht with Accessories - the appellant had not submitted any documentary evidences with regard to the purchase of the said goods and accordingly, the determination of the value of such goods under Rule 9 ibid is justified and thus, cannot be interfered with at this juncture. Therefore, the differential duty along with interest in the impugned order on the said goods is proper and justified and are liable for confiscation under Section 111 (l) ibid. - AT
Valuation of imported goods - Brand New Azimut 68 Motor Yacht with Accessories - the appellant had not submitted any documentary evidences with regard to the purchase of the said goods and accordingly, the determination of the value of such goods under Rule 9 ibid is justified and thus, cannot be interfered with at this juncture. Therefore, the differential duty along with interest in the impugned order on the said goods is proper and justified and are liable for confiscation under Section 111 (l) ibid. - AT
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