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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Benefit of the Customs Tariff [Determination of Origin of Products under the Duty Free Tariff Preference Scheme for Least Developed Countries) Rules, 2015 - N/N. 96/2008-Custom, dated 13.08.2008 - benefit denied to the petitioner herein on the basis that there is no provision for third country invoicing in the relevant rules - The High court intervenes and quashes the impugned appellate order due to its failure to address the petitioner's contentions. The matter is remanded to the appellate authority for reconsideration, with a directive to provide a reasonable opportunity for the petitioner.
Benefit of the Customs Tariff [Determination of Origin of Products under the Duty Free Tariff Preference Scheme for Least Developed Countries) Rules, 2015 - N/N. 96/2008-Custom, dated 13.08.2008 - benefit denied to the petitioner herein on the basis that there is no provision for third country invoicing in the relevant rules - The High court intervenes and quashes the impugned appellate order due to its failure to address the petitioner's contentions. The matter is remanded to the appellate authority for reconsideration, with a directive to provide a reasonable opportunity for the petitioner.
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