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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Revocation of Customs Broker licence - In the instant case the report of inquiry was not furnished to the Appellant seeking his response in compliance to para 6 of Regulation 17 apparently for the reason that the report was not against the Appellant. However, in complete disregard of the report and in the absence of a representation from the Appellant Customs Broker, the Commissioner had prepared a disagreement memo instead of passing an order revoking the suspension of the licence or, in the worst scenario, confirming the revocation of licence itself, in compliance to para 7 though before such revocation order Appellant was noticed to submit his response - The licence of Customs Broker is restored back to him. - AT
Revocation of Customs Broker licence - In the instant case the report of inquiry was not furnished to the Appellant seeking his response in compliance to para 6 of Regulation 17 apparently for the reason that the report was not against the Appellant. However, in complete disregard of the report and in the absence of a representation from the Appellant Customs Broker, the Commissioner had prepared a disagreement memo instead of passing an order revoking the suspension of the licence or, in the worst scenario, confirming the revocation of licence itself, in compliance to para 7 though before such revocation order Appellant was noticed to submit his response - The licence of Customs Broker is restored back to him. - AT
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