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 - abating the fraud - ex-superintendent of Central Excise with other person - Rebate claim - habitual offender - Appellant had perpetuated the fraud - The economic offenders/ white collared criminals need to be dealt in the strictest manner so as maintain uniformity and well being in the society and not endanger the economy of the country - It has been settled by various authorities that the word “possession” or similar phrases used in the statute do not imply physical possession of the goods but would imply possession in law. - AT
Levy of penalty - abating the fraud - ex-superintendent of Central Excise with other person - Rebate claim - habitual offender - Appellant had perpetuated the fraud - The economic offenders/ white collared criminals need to be dealt in the strictest manner so as maintain uniformity and well being in the society and not endanger the economy of the country - It has been settled by various authorities that the word “possession” or similar phrases used in the statute do not imply physical possession of the goods but would imply possession in law. - AT
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