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 case involving alleged clandestine removal of sponge iron, where revenue authorities relied primarily on unverified pendrive evidence without substantive corroborative documentation. The tribunal critically examined the evidentiary basis and found insufficient substantiation for the claims. Consequently, the tribunal set aside the confirmed demand of Rs.1,47,93,916/- along with associated interest and penalties. The key legal determination centered on the inadequacy of evidence, specifically highlighting the lack of comprehensive investigative procedures, absence of verifiable input-output analysis, and reliance on unattributed digital records. The appellate order comprehensively rejected the revenue's case due to evidentiary insufficiency and procedural non-compliance.
CESTAT adjudicated a case involving alleged clandestine removal of sponge iron, where revenue authorities relied primarily on unverified pendrive evidence without substantive corroborative documentation. The tribunal critically examined the evidentiary basis and found insufficient substantiation for the claims. Consequently, the tribunal set aside the confirmed demand of Rs.1,47,93,916/- along with associated interest and penalties. The key legal determination centered on the inadequacy of evidence, specifically highlighting the lack of comprehensive investigative procedures, absence of verifiable input-output analysis, and reliance on unattributed digital records. The appellate order comprehensively rejected the revenue's case due to evidentiary insufficiency and procedural non-compliance.
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