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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Imposition of penalty u/s 112(a) of the Customs Act, 1962 - fraudulent import in the name of dummy IECs with mis-declaration in description and value inputs - Abetment - The tribunal held that, the appellant’s own statement afford sufficient corroboration to those statements. Cross-examination is vital for meeting out the allegations But when there is sufficient corroboration to those allegations, denial of cross-examination cannot be held prejudicial - there are sufficient ingredients for commission of offence by the appellant. - Demand with penalties confirmed.
Imposition of penalty u/s 112(a) of the Customs Act, 1962 - fraudulent import in the name of dummy IECs with mis-declaration in description and value inputs - Abetment - The tribunal held that, the appellant’s own statement afford sufficient corroboration to those statements. Cross-examination is vital for meeting out the allegations But when there is sufficient corroboration to those allegations, denial of cross-examination cannot be held prejudicial - there are sufficient ingredients for commission of offence by the appellant. - Demand with penalties confirmed.
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