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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Seeking clearance of imported goods - e-waste/hazardous waste - imported medical devices - The Appellate Tribunal found in favor of the appellant on all grounds. They held that the absence of a valid SCN deprived the Adjudicating Authority of jurisdiction to pass the order. Additionally, considering the evidence presented, including certification by a Chartered Engineer, the Tribunal concluded that the imported goods did not qualify as waste under the relevant rules. The certification of the goods' residual life further supported this finding.
Seeking clearance of imported goods - e-waste/hazardous waste - imported medical devices - The Appellate Tribunal found in favor of the appellant on all grounds. They held that the absence of a valid SCN deprived the Adjudicating Authority of jurisdiction to pass the order. Additionally, considering the evidence presented, including certification by a Chartered Engineer, the Tribunal concluded that the imported goods did not qualify as waste under the relevant rules. The certification of the goods' residual life further supported this finding.
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