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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Valuation of imported goods was rejected by authorities, enhancing value based on contemporaneous import data of similar goods. However, transaction value declared by appellant was determinable u/s 14 of Customs Act, 1962, read with Rule 3(1) of Valuation Rules. Rejecting declared transaction value without legal sanction is unsustainable. NIDB data alone cannot justify value enhancement, as it merely serves as a guideline unless value falls within parameters of identical or similar goods. Rejection of transaction value and value enhancement by department are unsustainable. Impugned orders set aside. Appeal allowed.
Valuation of imported goods was rejected by authorities, enhancing value based on contemporaneous import data of similar goods. However, transaction value declared by appellant was determinable u/s 14 of Customs Act, 1962, read with Rule 3(1) of Valuation Rules. Rejecting declared transaction value without legal sanction is unsustainable. NIDB data alone cannot justify value enhancement, as it merely serves as a guideline unless value falls within parameters of identical or similar goods. Rejection of transaction value and value enhancement by department are unsustainable. Impugned orders set aside. Appeal allowed.
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