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 adjudicated a customs broker (CB) case involving alleged regulatory violations related to export documentation. The tribunal partially allowed the appeal, finding no substantive evidence of deliberate misconduct in regulatory breaches under Regulations 10(a), 10(d), and 10(n). While exculpating the CB from direct responsibility for exporters' fraudulent actions, the tribunal nonetheless imposed a reduced penalty of Rs 25,000 (from original Rs 50,000), recognizing the CB's professional obligations. Key outcomes include: (i) CB license revocation set aside, (ii) security deposit forfeiture rescinded, and (iii) penalty substantially mitigated, acknowledging the CB's peripheral role in potential export documentation irregularities.
CESTAT adjudicated a customs broker (CB) case involving alleged regulatory violations related to export documentation. The tribunal partially allowed the appeal, finding no substantive evidence of deliberate misconduct in regulatory breaches under Regulations 10(a), 10(d), and 10(n). While exculpating the CB from direct responsibility for exporters' fraudulent actions, the tribunal nonetheless imposed a reduced penalty of Rs 25,000 (from original Rs 50,000), recognizing the CB's professional obligations. Key outcomes include: (i) CB license revocation set aside, (ii) security deposit forfeiture rescinded, and (iii) penalty substantially mitigated, acknowledging the CB's peripheral role in potential export documentation irregularities.
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