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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Valuation - If all other conditions are satisfied such as import of the goods from the manufacturer then merely because the procedure of prior written approval cannot come in the way of allowing the 10% variation from the PLATTS rate to arrive at the valuation - the standing order itself is a guideline and not an Act or Rules made under Customs Act. - The noncompliance of standing order is only a procedure lapse, for which the substantive benefit of the 10% variation cannot be denied - AT
Valuation - If all other conditions are satisfied such as import of the goods from the manufacturer then merely because the procedure of prior written approval cannot come in the way of allowing the 10% variation from the PLATTS rate to arrive at the valuation - the standing order itself is a guideline and not an Act or Rules made under Customs Act. - The noncompliance of standing order is only a procedure lapse, for which the substantive benefit of the 10% variation cannot be denied - AT
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