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 - Imported 20 MT of Aluminium powder 99.7% - The Department contended that the declared value was low, considering it a related party transaction due to the overseas supplier's connection to the appellant. The appellant argued that they paid duty under protest and provided evidence such as details of contemporaneous imports, which were not considered by the authorities. The Tribunal found merit in the appellant's arguments, particularly noting the lack of detailed explanation for the enhancement of value. Consequently, they set aside the impugned order and remanded the matter to the adjudicating authority for reconsideration.
Valuation - Imported 20 MT of Aluminium powder 99.7% - The Department contended that the declared value was low, considering it a related party transaction due to the overseas supplier's connection to the appellant. The appellant argued that they paid duty under protest and provided evidence such as details of contemporaneous imports, which were not considered by the authorities. The Tribunal found merit in the appellant's arguments, particularly noting the lack of detailed explanation for the enhancement of value. Consequently, they set aside the impugned order and remanded the matter to the adjudicating authority for reconsideration.
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