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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Valuation - payment of CVD on MRP basis - Demand of differential duty of customs for the extended period of limitation, along with imposition of penalty - It is mentioned in the Show-Cause Notice that investigation was started by the department only after declaration of MRP/RSP suo moto by the appellant in the Bill of Entry filed in October, 2009 and subsequent Bills of Entry. - no case has been made of by the revenue that the appellant, in spite of having knowledge of such compliance towards MRP, have deliberately not declared. - the demand shall be limited to the normal period of limitation - AT
Valuation - payment of CVD on MRP basis - Demand of differential duty of customs for the extended period of limitation, along with imposition of penalty - It is mentioned in the Show-Cause Notice that investigation was started by the department only after declaration of MRP/RSP suo moto by the appellant in the Bill of Entry filed in October, 2009 and subsequent Bills of Entry. - no case has been made of by the revenue that the appellant, in spite of having knowledge of such compliance towards MRP, have deliberately not declared. - the demand shall be limited to the normal period of limitation - AT
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