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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The case involved a dispute regarding the demand of differential duty u/s 28 of the Customs Act, 1962 for using a helicopter for NSOP (Charter) despite having a permit for NSOP (Passenger). The Tribunal held that the permit for NSOP (Passenger) can be used for charter services based on previous rulings. The definition of 'Private Aircraft' was clarified, stating that if an aircraft is used for remuneration, it is considered a public transport aircraft. The appellant's use of the helicopter for commercial flights fell under the category of 'Private Aircraft'. As the helicopter was used for non-scheduled (Passenger) services, there was no violation of the exemption notification. The impugned order was set aside, and the appeal was allowed.
The case involved a dispute regarding the demand of differential duty u/s 28 of the Customs Act, 1962 for using a helicopter for NSOP (Charter) despite having a permit for NSOP (Passenger). The Tribunal held that the permit for NSOP (Passenger) can be used for charter services based on previous rulings. The definition of 'Private Aircraft' was clarified, stating that if an aircraft is used for remuneration, it is considered a public transport aircraft. The appellant's use of the helicopter for commercial flights fell under the category of 'Private Aircraft'. As the helicopter was used for non-scheduled (Passenger) services, there was no violation of the exemption notification. The impugned order was set aside, and the appeal was allowed.
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