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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Remission of duty - damage due to the arson indulged in by the mob of the workers - From a harmonious reading of the Rule would clarify that when the loss is caused by natural causes or unavoidable accident, the Assessee should be granted remission of duty. Coming to the factual matrix of this case, it is very clear that the arson indulged in by the mob of the workers was absolutely not an act which could have been avoided or controlled by the Management of the Appellant - Benefit of remission of duty allowed - AT
Remission of duty - damage due to the arson indulged in by the mob of the workers - From a harmonious reading of the Rule would clarify that when the loss is caused by natural causes or unavoidable accident, the Assessee should be granted remission of duty. Coming to the factual matrix of this case, it is very clear that the arson indulged in by the mob of the workers was absolutely not an act which could have been avoided or controlled by the Management of the Appellant - Benefit of remission of duty allowed - AT
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