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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This case concerns the classification and duty rate applicable to food preparations sold by the appellant in sealed containers. The Revenue classified the goods under 21069099, considering them not sold in sealed containers, thus attracting duty under Serial No. 38. However, the Tribunal held that since the appellant sold the goods in packed/sealed condition, the correct classification was 210690 under Serial No. 37, which attracted nil duty rate as per Notification 12/2012-CE. Consequently, the demand of duty on the classification issue was set aside, and no penalty was imposable. The Tribunal allowed the appeal, ruling that the appellant was entitled to the benefit under Serial No. 37 of the Notification.
This case concerns the classification and duty rate applicable to food preparations sold by the appellant in sealed containers. The Revenue classified the goods under 21069099, considering them not sold in sealed containers, thus attracting duty under Serial No. 38. However, the Tribunal held that since the appellant sold the goods in packed/sealed condition, the correct classification was 210690 under Serial No. 37, which attracted nil duty rate as per Notification 12/2012-CE. Consequently, the demand of duty on the classification issue was set aside, and no penalty was imposable. The Tribunal allowed the appeal, ruling that the appellant was entitled to the benefit under Serial No. 37 of the Notification.
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