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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Rejection of provisional release of goods imported by the appellant - Secondary grade goods - Prime goods or not - Department is that the appellants forged Mill Test Certificate and that goods imported by the appellant, under seizure are not BIS compliant - The department should not have any objection in releasing the goods provisionally. However, we are of the opinion that at the same time the interest of the Revenue is to be safeguarded. - AT
Rejection of provisional release of goods imported by the appellant - Secondary grade goods - Prime goods or not - Department is that the appellants forged Mill Test Certificate and that goods imported by the appellant, under seizure are not BIS compliant - The department should not have any objection in releasing the goods provisionally. However, we are of the opinion that at the same time the interest of the Revenue is to be safeguarded. - AT
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