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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Violation of principles of natural justice - Handling of Cargo in Customs Areas - Setting up of ICD - Revocation of approvals granted u/s 8, Section 45 of Customs Act,1962 read with Regulation 10 of (HCCAR, 2009) - The argument of the Revenue is that there would be some GST implications if both the DTA unit as well as Customs notified area are situated in the same premises. It is also seen from the records that such apprehensions have not been spelt out in the order. - Department are directed to issue a notice and adjudicate the issue after getting reply - AT
Violation of principles of natural justice - Handling of Cargo in Customs Areas - Setting up of ICD - Revocation of approvals granted u/s 8, Section 45 of Customs Act,1962 read with Regulation 10 of (HCCAR, 2009) - The argument of the Revenue is that there would be some GST implications if both the DTA unit as well as Customs notified area are situated in the same premises. It is also seen from the records that such apprehensions have not been spelt out in the order. - Department are directed to issue a notice and adjudicate the issue after getting reply - AT
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