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-determination of value - Misdeclaration - reclassifying of the impugned goods - Revenue Appeal - The appeal before the Appellate Tribunal revolved around the failure to confiscate goods and impose penalties under the Customs Act, 1962. The appellant contended that the respondent had misdeclared the goods and claimed improper exemptions, while the respondent maintained that there was no misdeclaration and that procedural requirements had not been met. The Tribunal found no merit in the appellant's arguments and upheld the impugned order, emphasizing the lack of evidence of misdeclaration or evasion of duty. It also noted the absence of a show cause notice before confiscation, leading to the dismissal of the appeal.
Re-determination of value - Misdeclaration - reclassifying of the impugned goods - Revenue Appeal - The appeal before the Appellate Tribunal revolved around the failure to confiscate goods and impose penalties under the Customs Act, 1962. The appellant contended that the respondent had misdeclared the goods and claimed improper exemptions, while the respondent maintained that there was no misdeclaration and that procedural requirements had not been met. The Tribunal found no merit in the appellant's arguments and upheld the impugned order, emphasizing the lack of evidence of misdeclaration or evasion of duty. It also noted the absence of a show cause notice before confiscation, leading to the dismissal of the appeal.
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