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's appeal challenging penalty allegations for alleged regulatory violations. The tribunal found no intentional misconduct by the broker, noting the authorization letter from reconstituted firm's partners validating the broker's actions. The tribunal critically examined the documentary evidence and determined that the broker was unaware of the firm's constitutional changes and acted within authorized parameters. The department's allegations of violating Regulation 11(d) and 11(n) of Customs Brokers Licensing Regulations were deemed unsubstantiated. The tribunal conclusively held that no deliberate wrongdoing was established, thereby setting aside the penalty order and allowing the broker's appeal with full exoneration.
CESTAT adjudicated a customs broker's appeal challenging penalty allegations for alleged regulatory violations. The tribunal found no intentional misconduct by the broker, noting the authorization letter from reconstituted firm's partners validating the broker's actions. The tribunal critically examined the documentary evidence and determined that the broker was unaware of the firm's constitutional changes and acted within authorized parameters. The department's allegations of violating Regulation 11(d) and 11(n) of Customs Brokers Licensing Regulations were deemed unsubstantiated. The tribunal conclusively held that no deliberate wrongdoing was established, thereby setting aside the penalty order and allowing the broker's appeal with full exoneration.
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