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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Invocation of larger (extended) period of limitation under Section 28(4) of the Customs Act, 1962 - The tribunal found sufficient evidence to support the allegation of willful mis-declaration aimed at evading import duty and compliance requirements. It noted the modus operandi outlined in the show-cause notice, where the importer imported goods in SKD condition to evade duty and compulsory compliance with regulations. Consequently, the tribunal upheld the application of Section 28(4) of the Customs Act, 1962.
Invocation of larger (extended) period of limitation under Section 28(4) of the Customs Act, 1962 - The tribunal found sufficient evidence to support the allegation of willful mis-declaration aimed at evading import duty and compliance requirements. It noted the modus operandi outlined in the show-cause notice, where the importer imported goods in SKD condition to evade duty and compulsory compliance with regulations. Consequently, the tribunal upheld the application of Section 28(4) of the Customs Act, 1962.
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