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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Imposition of Penalties u/s 112(a) & (b) and 114AA - Each appellant denied direct involvement or knowledge of the illegal activities, claiming to have played different roles in the importation process. - import of restricted / prohibited goods - The Tribunal carefully evaluated the submissions and evidence presented by both parties. It found that penalties were justified for appellants extensively involved in the importation process, including procurement, concealment, transportation, and distribution of goods. However, penalties were set aside for appellants with limited or no direct involvement in the illegal activities.
Imposition of Penalties u/s 112(a) & (b) and 114AA - Each appellant denied direct involvement or knowledge of the illegal activities, claiming to have played different roles in the importation process. - import of restricted / prohibited goods - The Tribunal carefully evaluated the submissions and evidence presented by both parties. It found that penalties were justified for appellants extensively involved in the importation process, including procurement, concealment, transportation, and distribution of goods. However, penalties were set aside for appellants with limited or no direct involvement in the illegal activities.
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