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 adjudicating authority classified the goods 'Bleach-9' manufactured by the assessee under chapter sub-heading 25.05, claiming NIL rate of duty, based on technical opinions stating it is raw clay/washed clay and not Activated Clay/Earth. The opinions mentioned that clay washed with water and dried is not termed 'Activated Clay,' and its properties remain the same as natural clay. The department did not adduce any evidence contradicting these findings, which formed the basis for classifying 'Bleach-9' under Tariff heading 25.05. As no fresh evidence was provided to challenge the orders, the Appellate Tribunal dismissed the department's appeal, upholding the classification under 25.05.
The adjudicating authority classified the goods 'Bleach-9' manufactured by the assessee under chapter sub-heading 25.05, claiming NIL rate of duty, based on technical opinions stating it is raw clay/washed clay and not Activated Clay/Earth. The opinions mentioned that clay washed with water and dried is not termed 'Activated Clay,' and its properties remain the same as natural clay. The department did not adduce any evidence contradicting these findings, which formed the basis for classifying 'Bleach-9' under Tariff heading 25.05. As no fresh evidence was provided to challenge the orders, the Appellate Tribunal dismissed the department's appeal, upholding the classification under 25.05.
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