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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Exemption from Basic Customs Duty - import of Lithium-Ion Batteries falling under Customs Tariff Heading 85076000 - Time limitation for submission of Country of Origin certificate - The appellant couldn't produce the COO certificate initially but later obtained it and appealed against the Commissioner (Appeals)'s decision, which rejected the appeal as time-barred and deemed the appellant ineligible for exemption. The Tribunal noted that the limitation period for filing appeals was extended due to the COVID-19 pandemic, thereby setting aside the rejection on grounds of being time-barred. The matter was remanded to the Commissioner (Appeals) for reconsideration, specifically regarding the retrospective issuance of the COO certificate and its implications on exemption eligibility.
Exemption from Basic Customs Duty - import of Lithium-Ion Batteries falling under Customs Tariff Heading 85076000 - Time limitation for submission of Country of Origin certificate - The appellant couldn't produce the COO certificate initially but later obtained it and appealed against the Commissioner (Appeals)'s decision, which rejected the appeal as time-barred and deemed the appellant ineligible for exemption. The Tribunal noted that the limitation period for filing appeals was extended due to the COVID-19 pandemic, thereby setting aside the rejection on grounds of being time-barred. The matter was remanded to the Commissioner (Appeals) for reconsideration, specifically regarding the retrospective issuance of the COO certificate and its implications on exemption eligibility.
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