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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Method of valuation - Revenue neutrality - Extended period of limitation - goods transferred to another unit for captive consumption - to be valued in accordance with Rule 8 of the Valuation Rules or under Rule 4 - the tribunal upheld the appellant's argument that the valuation should be done in accordance with CAS-4, as mandated by relevant circulars and legal precedents. The tribunal also found in favor of the appellant on the issue of limitation, ruling that the show-cause notice issued beyond the normal limitation period was barred.
Method of valuation - Revenue neutrality - Extended period of limitation - goods transferred to another unit for captive consumption - to be valued in accordance with Rule 8 of the Valuation Rules or under Rule 4 - the tribunal upheld the appellant's argument that the valuation should be done in accordance with CAS-4, as mandated by relevant circulars and legal precedents. The tribunal also found in favor of the appellant on the issue of limitation, ruling that the show-cause notice issued beyond the normal limitation period was barred.
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