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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Transaction value - Valuation (Customs) - Special or abnormal discount to the related buyers which were in excess of 3% discount - The Appellate Tribunal observed that the discounts were not deemed exclusive to related parties, and thus did not influence the transaction value. The Tribunal found that the department failed to provide concrete reasons to discard the declared transaction value. The arguments against accepting the transaction value were based on conjecture and lacked factual substantiation. In conclusion, the Tribunal set aside the impugned order, stating that the appellant had successfully proven that the declared price reflected the true transaction value.
Transaction value - Valuation (Customs) - Special or abnormal discount to the related buyers which were in excess of 3% discount - The Appellate Tribunal observed that the discounts were not deemed exclusive to related parties, and thus did not influence the transaction value. The Tribunal found that the department failed to provide concrete reasons to discard the declared transaction value. The arguments against accepting the transaction value were based on conjecture and lacked factual substantiation. In conclusion, the Tribunal set aside the impugned order, stating that the appellant had successfully proven that the declared price reflected the true transaction value.
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