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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Levy of penalty on Exporter and CHA - consignments of rice were exported to Iran but delivered/diverted/discharged at Jabel Ali Port, Dubai and sold in UAE - M/s. SSIGPL lost the ownership of the goods as soon as ‘let export order’ was issued by the Customs authorities. After the said let export order it was the responsibility of the Shipping Lines to ship the goods to the foreign buyer and the exporter having no control over the goods. - M/s. SSIGPL cannot be held responsible if the importer situated at Iran had given instruction to change the port from Bandar Abbas port to Jabel Ali port as after the ‘let export order’ was issued by the Customs authorities it was the importer at Iran who became the owner of the goods. - AT
Levy of penalty on Exporter and CHA - consignments of rice were exported to Iran but delivered/diverted/discharged at Jabel Ali Port, Dubai and sold in UAE - M/s. SSIGPL lost the ownership of the goods as soon as ‘let export order’ was issued by the Customs authorities. After the said let export order it was the responsibility of the Shipping Lines to ship the goods to the foreign buyer and the exporter having no control over the goods. - M/s. SSIGPL cannot be held responsible if the importer situated at Iran had given instruction to change the port from Bandar Abbas port to Jabel Ali port as after the ‘let export order’ was issued by the Customs authorities it was the importer at Iran who became the owner of the goods. - AT
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