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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Process amounting to manufacture - Change in Tariff Heading - buying tubes (stainless steel pipes) and then undertaking certain processes thereon, such as, upsetting, heat treatment, inspection, testing, threading and external coating, so that the pipes can be used for the purposes of oil drilling - The Tribunal finds that the processes undertaken by the appellant do not amount to 'manufacture,' citing precedents and the lack of substantial changes in the character or end-use of the products. - The Tribunal dismisses the Revenue's argument that a change in the tariff heading implies 'manufacture,' stating that such changes do not necessarily indicate manufacturing processes.
Process amounting to manufacture - Change in Tariff Heading - buying tubes (stainless steel pipes) and then undertaking certain processes thereon, such as, upsetting, heat treatment, inspection, testing, threading and external coating, so that the pipes can be used for the purposes of oil drilling - The Tribunal finds that the processes undertaken by the appellant do not amount to 'manufacture,' citing precedents and the lack of substantial changes in the character or end-use of the products. - The Tribunal dismisses the Revenue's argument that a change in the tariff heading implies 'manufacture,' stating that such changes do not necessarily indicate manufacturing processes.
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