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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Re-classification of Thorn - The Tribunal upheld the reclassification of the imported goods to CTI 76020090, agreeing with the authorities that the original classification was a mistake. - The Tribunal concurred with the absolute confiscation of the goods under the discussed sections of the Customs Act. However, it adjusted the penalties, allowing for the redemption of the confiscated goods upon payment of a fine, acknowledging that while the importer lacked a necessary license, there was no hazardous material in the goods that would pose a risk to society. - Penalties under section 114AA were set aside due to the lack of intentional misdeclaration.
Re-classification of Thorn - The Tribunal upheld the reclassification of the imported goods to CTI 76020090, agreeing with the authorities that the original classification was a mistake. - The Tribunal concurred with the absolute confiscation of the goods under the discussed sections of the Customs Act. However, it adjusted the penalties, allowing for the redemption of the confiscated goods upon payment of a fine, acknowledging that while the importer lacked a necessary license, there was no hazardous material in the goods that would pose a risk to society. - Penalties under section 114AA were set aside due to the lack of intentional misdeclaration.
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