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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC finds in favor of Petitioner, invalidating Respondent's classification decision due to procedural irregularities. The key violations include non-disclosure of critical documents in Show Cause Notice (SCN) and failure to address prior consistent classification orders. A test report confirming the product as an organic seaweed extract usable as vegetable fertilizer substantiates classification under CTH 3101. The court remanded the matter to Adjudicating Authority for de novo hearing, mandating document disclosure and requiring a reasoned order addressing all substantive arguments. The impugned order was set aside, effectively reinstating the Petitioner's original classification claim.
HC finds in favor of Petitioner, invalidating Respondent's classification decision due to procedural irregularities. The key violations include non-disclosure of critical documents in Show Cause Notice (SCN) and failure to address prior consistent classification orders. A test report confirming the product as an organic seaweed extract usable as vegetable fertilizer substantiates classification under CTH 3101. The court remanded the matter to Adjudicating Authority for de novo hearing, mandating document disclosure and requiring a reasoned order addressing all substantive arguments. The impugned order was set aside, effectively reinstating the Petitioner's original classification claim.
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