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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Aircraft pertaining to international flights - excess ATF on board - Inclusion of cost of transportation of remnant ATF in the IOCL price, on which the Customs duty has been discharged - Rule 10 (2) of the Valuation Rules, 2007 - As the issue has already been settled by the Larger Bench of this Tribunal in the assessee’s own case, therefore, the transportation cost is not to be included in the value of remnant ATF for determining the assessable value in this case. - AT
Aircraft pertaining to international flights - excess ATF on board - Inclusion of cost of transportation of remnant ATF in the IOCL price, on which the Customs duty has been discharged - Rule 10 (2) of the Valuation Rules, 2007 - As the issue has already been settled by the Larger Bench of this Tribunal in the assessee’s own case, therefore, the transportation cost is not to be included in the value of remnant ATF for determining the assessable value in this case. - AT
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