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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Customs Act - Importer paid import duty on fresh apples through scrips issued under FMS, FPS, and VKGUY schemes, endorsed by officers. Subsequently, duty paid in cash with interest. Show cause notice issued invoking Section 28(4) for suppression and larger period of limitation unjustified. No culpability, fraud, or intent to evade duty proven. Penalty u/s 114A initially imposed Rs. 23 lakh, later enhanced to Rs. 1,72,61,089 set aside. Imported goods not liable for confiscation. Appeal allowed by CESTAT.
Customs Act - Importer paid import duty on fresh apples through scrips issued under FMS, FPS, and VKGUY schemes, endorsed by officers. Subsequently, duty paid in cash with interest. Show cause notice issued invoking Section 28(4) for suppression and larger period of limitation unjustified. No culpability, fraud, or intent to evade duty proven. Penalty u/s 114A initially imposed Rs. 23 lakh, later enhanced to Rs. 1,72,61,089 set aside. Imported goods not liable for confiscation. Appeal allowed by CESTAT.
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