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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Clandestine removal - The department relied on statements, diaries, and records, which the appellants contested, citing coercion and lack of corroboration. The Tribunal found discrepancies in the evidence, particularly regarding the validity of diaries and reliability of statements. Lack of tangible evidence and corroboration led to the dismissal of duty demands and penalties imposed on the appellants. The Tribunal emphasized the importance of corroborative evidence in such cases and concluded in favor of the appellants.
Clandestine removal - The department relied on statements, diaries, and records, which the appellants contested, citing coercion and lack of corroboration. The Tribunal found discrepancies in the evidence, particularly regarding the validity of diaries and reliability of statements. Lack of tangible evidence and corroboration led to the dismissal of duty demands and penalties imposed on the appellants. The Tribunal emphasized the importance of corroborative evidence in such cases and concluded in favor of the appellants.
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