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 importer's appeal, granting exemption from Basic Customs Duty on walnut imports from Afghanistan. Despite department's allegations of potential certificate manipulation and conflicting tags, the tribunal found overwhelming documentary evidence confirming Afghan origin. The tribunal emphasized that verified Certificate of Origin by relevant authorities under SAFTA constitutes conclusive evidence, and absence of denial by Afghan governmental authorities validates the origin claim. Consequently, the exemption benefit under Notification No. 99/2011-Cus was upheld, rejecting departmental contentions based on speculative evidence.
CESTAT allowed importer's appeal, granting exemption from Basic Customs Duty on walnut imports from Afghanistan. Despite department's allegations of potential certificate manipulation and conflicting tags, the tribunal found overwhelming documentary evidence confirming Afghan origin. The tribunal emphasized that verified Certificate of Origin by relevant authorities under SAFTA constitutes conclusive evidence, and absence of denial by Afghan governmental authorities validates the origin claim. Consequently, the exemption benefit under Notification No. 99/2011-Cus was upheld, rejecting departmental contentions based on speculative evidence.
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