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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Classification of imported goods - Narrow Woven Fabric Webbing - The tribunal noted that the appellant's actions in misclassifying goods from a specific country indicated an attempt to evade duty payment, justifying the demand of customs duty. - The tribunal affirmed the decision to confirm the demand of customs duty, emphasizing that the appellant's concession regarding duty payment indicated acknowledgment of the duty liability, regardless of the absence of collusion or willful misstatement. - Regarding the non-confiscation of goods and absence of penalties under certain sections, the tribunal ruled in favor of the Commissioner's decision. It reasoned that while there was no explicit finding of collusion or willful misstatement to warrant penalties, the appellant's concession of duty payment justified the demand.
Classification of imported goods - Narrow Woven Fabric Webbing - The tribunal noted that the appellant's actions in misclassifying goods from a specific country indicated an attempt to evade duty payment, justifying the demand of customs duty. - The tribunal affirmed the decision to confirm the demand of customs duty, emphasizing that the appellant's concession regarding duty payment indicated acknowledgment of the duty liability, regardless of the absence of collusion or willful misstatement. - Regarding the non-confiscation of goods and absence of penalties under certain sections, the tribunal ruled in favor of the Commissioner's decision. It reasoned that while there was no explicit finding of collusion or willful misstatement to warrant penalties, the appellant's concession of duty payment justified the demand.
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