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 Customs, Excise and Service Tax Appellate Tribunal set aside the order cancelling the public bonded warehouse licence issued to the Appellant u/s 58B(1) of the Customs Act, 1962. The Tribunal held that the delay in installing the audit trail facility in the computerized system was due to circumstances beyond the Appellant's control, and this alone did not warrant licence cancellation without providing an opportunity to comply. Regarding the theft incident, the Tribunal observed that one isolated incident cannot conclude inadequate security measures, and the Department can advise enhancing security instead of licence revocation. The matter was remanded for fresh examination and verification of the warehouse infrastructure's compliance with regulations before taking appropriate action.
The Customs, Excise and Service Tax Appellate Tribunal set aside the order cancelling the public bonded warehouse licence issued to the Appellant u/s 58B(1) of the Customs Act, 1962. The Tribunal held that the delay in installing the audit trail facility in the computerized system was due to circumstances beyond the Appellant's control, and this alone did not warrant licence cancellation without providing an opportunity to comply. Regarding the theft incident, the Tribunal observed that one isolated incident cannot conclude inadequate security measures, and the Department can advise enhancing security instead of licence revocation. The matter was remanded for fresh examination and verification of the warehouse infrastructure's compliance with regulations before taking appropriate action.
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