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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Scope of SCN - Setting a new case which travelled beyond the SCN - Original authority has clearly observed that the said chapter note was applicable in the case and the goods were not classifiable under chapter 5907. Having done so he should have dropped the demand which was made under heading 5907.12. However without assigning any reason he determines the classification under Chapter 54 suo motto without putting the appellant to notice - demand set aside - AT
Scope of SCN - Setting a new case which travelled beyond the SCN - Original authority has clearly observed that the said chapter note was applicable in the case and the goods were not classifiable under chapter 5907. Having done so he should have dropped the demand which was made under heading 5907.12. However without assigning any reason he determines the classification under Chapter 54 suo motto without putting the appellant to notice - demand set aside - AT
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