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 imported goods "MPC7E MRATE IRB 10G/40G 100 QSFP28-MPC-L3 Line Cards [Router Line Cards]" under Customs Tariff Item (CTI) 8517 69 30 or 8517 62 90. Tribunal previously held in appellant's own case that Router Line Cards are Populated PCBs classifiable under CTI 8517 70 10 covering 'populated, loaded or stuffed printed circuit boards' attracting NIL duty rate. Principal Commissioner's order classifying under CTI 8517 62 90 unsustainable. Appellant's classification under CTI 8517 70 10 upheld. Principal Commissioner's order set aside. Appeal allowed.
Classification dispute regarding imported goods "MPC7E MRATE IRB 10G/40G 100 QSFP28-MPC-L3 Line Cards [Router Line Cards]" under Customs Tariff Item (CTI) 8517 69 30 or 8517 62 90. Tribunal previously held in appellant's own case that Router Line Cards are Populated PCBs classifiable under CTI 8517 70 10 covering 'populated, loaded or stuffed printed circuit boards' attracting NIL duty rate. Principal Commissioner's order classifying under CTI 8517 62 90 unsustainable. Appellant's classification under CTI 8517 70 10 upheld. Principal Commissioner's order set aside. Appeal allowed.
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