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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Project Import - fulfillment of post import conditions - In the first place issuance of Show Cause Notice in itself is grossly misplaced and misdirected. Moreover, this has been compounded by the Ld. Adjudicating Authority by adjudicating the matter against the appellants. Despite clearly taking note of the factual position, disallowing the benefit of the project import regulations and the concessional rate of duty is certainly an error of judgement - AT
Project Import - fulfillment of post import conditions - In the first place issuance of Show Cause Notice in itself is grossly misplaced and misdirected. Moreover, this has been compounded by the Ld. Adjudicating Authority by adjudicating the matter against the appellants. Despite clearly taking note of the factual position, disallowing the benefit of the project import regulations and the concessional rate of duty is certainly an error of judgement - AT
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