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 appellate proceedings involving silver jewelry manufacturer. The tribunal ruled in favor of the appellant, addressing multiple key issues: (1) goods classified under CETH 7113 without evidence of precious stone studding, (2) compliance with Notification No. 12/2012 exemption conditions, (3) hedging activities not considered trading, (4) no willful suppression of facts justifying extended limitation period, and (5) ineligible credit demand previously dropped. The tribunal comprehensively rejected the revenue's contentions across classification, duty exemption, and credit-related challenges. The appeal was ultimately allowed, substantially vindicating the appellant's legal and procedural positions across multiple contested aspects of the excise duty dispute.
CESTAT appellate proceedings involving silver jewelry manufacturer. The tribunal ruled in favor of the appellant, addressing multiple key issues: (1) goods classified under CETH 7113 without evidence of precious stone studding, (2) compliance with Notification No. 12/2012 exemption conditions, (3) hedging activities not considered trading, (4) no willful suppression of facts justifying extended limitation period, and (5) ineligible credit demand previously dropped. The tribunal comprehensively rejected the revenue's contentions across classification, duty exemption, and credit-related challenges. The appeal was ultimately allowed, substantially vindicating the appellant's legal and procedural positions across multiple contested aspects of the excise duty dispute.
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