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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Classification of imported goods - Boronated Calcium Nitrate - to be classified under CTH 3102 60 00 of the First Schedule to the Customs Tariff Act, 1975 or not - concessional rate of 5% BCD - The Appellant argued that their submissions were not considered and relevant reports were not provided during the proceedings, violating principles of natural justice. The Tribunal, emphasizing the need for clarity on the product's nature, set aside the impugned order and remanded the matter for reconsideration by the Adjudicating Authority.
Classification of imported goods - Boronated Calcium Nitrate - to be classified under CTH 3102 60 00 of the First Schedule to the Customs Tariff Act, 1975 or not - concessional rate of 5% BCD - The Appellant argued that their submissions were not considered and relevant reports were not provided during the proceedings, violating principles of natural justice. The Tribunal, emphasizing the need for clarity on the product's nature, set aside the impugned order and remanded the matter for reconsideration by the Adjudicating Authority.
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