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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Lvey of maximum penlaty on Customs Broker - Learned Adjudicating Authority finds that the appellant has violated the provisions of CBLR, 2018 and yet, he finds that the violations do not warrant revocation of license. It is very difficult to understand as to how the allegations would invite a maximum penalty under Rule 18 ibid. One has to conclude that if the violations are not grave enough to warrant revocation of license, they do not warrant maximum penalty under Rule 18 also. - AT
Lvey of maximum penlaty on Customs Broker - Learned Adjudicating Authority finds that the appellant has violated the provisions of CBLR, 2018 and yet, he finds that the violations do not warrant revocation of license. It is very difficult to understand as to how the allegations would invite a maximum penalty under Rule 18 ibid. One has to conclude that if the violations are not grave enough to warrant revocation of license, they do not warrant maximum penalty under Rule 18 also. - AT
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