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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Demand of differential Central Excise Duty with interest and penalty - inflating freight charges through their dummy transport unit - The Tribunal affirmed the confirmation of the differential duty, penalties, and interest imposed by the Assistant Commissioner, based on the findings of undervaluation and evasion of excise duty. Regarding the determination of assessable value, the Tribunal analyzed the provisions of Rule 5 of the Central Excise Valuation Rules and Section 4(1)(a) of the Act. However, it found no merit in the appellant's argument and upheld the impugned orders.
Demand of differential Central Excise Duty with interest and penalty - inflating freight charges through their dummy transport unit - The Tribunal affirmed the confirmation of the differential duty, penalties, and interest imposed by the Assistant Commissioner, based on the findings of undervaluation and evasion of excise duty. Regarding the determination of assessable value, the Tribunal analyzed the provisions of Rule 5 of the Central Excise Valuation Rules and Section 4(1)(a) of the Act. However, it found no merit in the appellant's argument and upheld the impugned orders.
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