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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Assessment of sales shown in accounts at low prices - Benefit of exemption from VAT - sale of footwear - The language of the section is specific insofar as it states that the pricing should be 'abnormally low' when compared to the 'prevailing market price of such goods'. The prevailing market price must be taken into account which means that comparison must have been arrived at as between the prices of the manufacturer/petitioner and other identically placed manufacturers. This has admittedly not been done. - HC
Assessment of sales shown in accounts at low prices - Benefit of exemption from VAT - sale of footwear - The language of the section is specific insofar as it states that the pricing should be 'abnormally low' when compared to the 'prevailing market price of such goods'. The prevailing market price must be taken into account which means that comparison must have been arrived at as between the prices of the manufacturer/petitioner and other identically placed manufacturers. This has admittedly not been done. - HC
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