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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Refund claim of late fee mistakenly paid - late fee waived off by public notice no.21/2020 - It is found that the Revenue is taking a contradictory stand in as much as on the one hand, it claims that the refund of late fees is not governed by the provisions of Section 27 of the Customs Act 1962 and on the other, they find that the order of assessment being not challenged, they cannot be challenged by taking the route of refund. - AT
Refund claim of late fee mistakenly paid - late fee waived off by public notice no.21/2020 - It is found that the Revenue is taking a contradictory stand in as much as on the one hand, it claims that the refund of late fees is not governed by the provisions of Section 27 of the Customs Act 1962 and on the other, they find that the order of assessment being not challenged, they cannot be challenged by taking the route of refund. - AT
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