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 allowed the appeal, holding that the valuation of assorted leaf springs must be conducted under Section 4 of the Central Excise Act, 1944, not Section 4A. The tribunal found the revenue authorities' computational methodology lacking legal basis, with valuation based on erroneous presumptions and mathematical exercises. The goods were cleared loose without packaging, thus not qualifying as retail packages under Legal Metrology Rules. The demand and associated penalties were set aside due to insufficient evidence and improper stock verification procedures during the original investigation.
CESTAT allowed the appeal, holding that the valuation of assorted leaf springs must be conducted under Section 4 of the Central Excise Act, 1944, not Section 4A. The tribunal found the revenue authorities' computational methodology lacking legal basis, with valuation based on erroneous presumptions and mathematical exercises. The goods were cleared loose without packaging, thus not qualifying as retail packages under Legal Metrology Rules. The demand and associated penalties were set aside due to insufficient evidence and improper stock verification procedures during the original investigation.
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