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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CESTAT ruled against inclusion of 4% running royalty in transaction value of imported goods under Rule 10(1)(c) of Customs Valuation Rules, 2007. The Tribunal found that royalty payments were not directly related to imported goods, as they were calculated on net sales value of manufactured products. The goods were not procured from the group company, and no conditions mandated royalty payment for sale. The Explanation to Rule 10(1)(c) requires royalty to be paid for a process applied to imported goods, which was not applicable here. Since royalty was neither paid nor payable specifically for imported goods, and no sale conditions existed, CESTAT held its addition to import value was incorrect. Appeal allowed with order setting aside Commissioner's decision.
CESTAT ruled against inclusion of 4% running royalty in transaction value of imported goods under Rule 10(1)(c) of Customs Valuation Rules, 2007. The Tribunal found that royalty payments were not directly related to imported goods, as they were calculated on net sales value of manufactured products. The goods were not procured from the group company, and no conditions mandated royalty payment for sale. The Explanation to Rule 10(1)(c) requires royalty to be paid for a process applied to imported goods, which was not applicable here. Since royalty was neither paid nor payable specifically for imported goods, and no sale conditions existed, CESTAT held its addition to import value was incorrect. Appeal allowed with order setting aside Commissioner's decision.
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