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 appellant company, part of a group, was involved in clandestine removal of imported partially oriented yarn (PFY) into the local market, breaching Notification No. 59 of 1998 for manufacture of export goods. This diversion occurred in connivance with brokers and buyers to obtain cash sale proceeds. Consequently, the demand for customs duties on seized yarns from Jay Krishna Sizers and Carewell Rayons Pvt. Ltd., and the imposition of penalty on the appellant, were upheld. The High Court dismissed the appeal, finding no substantial question of law arising from the Tribunal's order.
The appellant company, part of a group, was involved in clandestine removal of imported partially oriented yarn (PFY) into the local market, breaching Notification No. 59 of 1998 for manufacture of export goods. This diversion occurred in connivance with brokers and buyers to obtain cash sale proceeds. Consequently, the demand for customs duties on seized yarns from Jay Krishna Sizers and Carewell Rayons Pvt. Ltd., and the imposition of penalty on the appellant, were upheld. The High Court dismissed the appeal, finding no substantial question of law arising from the Tribunal's order.
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