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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Classification dispute regarding drilling rigs mounted on truck chassis/crawler - whether under tariff heading 84.30 or 87.05 during 1986-1988. Supreme Court settled classification under 87.05 in appellant's own case. Once classification settled, appellant became eligible for exemption under Notification 242/86-CE applicable to Chapter 87.05 goods, even though initially not claimed. Tribunal followed precedent allowing exemption claim at later stage. Condition of notification requiring duty payment on chassis/equipment used deemed complied as all market goods presumed duty paid. Chassis and equipment for special purpose vehicles considered deemed duty paid. Impugned order set aside, appeal allowed.
Classification dispute regarding drilling rigs mounted on truck chassis/crawler - whether under tariff heading 84.30 or 87.05 during 1986-1988. Supreme Court settled classification under 87.05 in appellant's own case. Once classification settled, appellant became eligible for exemption under Notification 242/86-CE applicable to Chapter 87.05 goods, even though initially not claimed. Tribunal followed precedent allowing exemption claim at later stage. Condition of notification requiring duty payment on chassis/equipment used deemed complied as all market goods presumed duty paid. Chassis and equipment for special purpose vehicles considered deemed duty paid. Impugned order set aside, appeal allowed.
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