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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Valuation of goods - admissibility of discounts - adjustment of list price by giving different rebates / discounts referred to as Movement Plan Rebate (MPR) - The Tribunal upheld the appellant's contention that discounts passed on to buyers and known at the time of clearance should be considered for determining the assessable value. Additionally, they ruled in favor of the appellant regarding the limitation on demand, citing the absence of intent to evade duty and the non-disclosure of rebate adjustments in filed returns.
Valuation of goods - admissibility of discounts - adjustment of list price by giving different rebates / discounts referred to as Movement Plan Rebate (MPR) - The Tribunal upheld the appellant's contention that discounts passed on to buyers and known at the time of clearance should be considered for determining the assessable value. Additionally, they ruled in favor of the appellant regarding the limitation on demand, citing the absence of intent to evade duty and the non-disclosure of rebate adjustments in filed returns.
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