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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Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
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