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 appeals, invalidating the Principal Commissioner's order by finding critical evidentiary deficiencies. The tribunal determined that e-mail printouts were inadmissible due to lack of proper authentication, absence of contextual verification, and failure to establish direct relevance to the appellant's transaction. Without substantive evidence challenging the declared transaction value, the tribunal set aside the order for redemption fine and penalties, effectively upholding the appellant's original transaction value declaration for imported iron screws from China.
CESTAT allowed the appeals, invalidating the Principal Commissioner's order by finding critical evidentiary deficiencies. The tribunal determined that e-mail printouts were inadmissible due to lack of proper authentication, absence of contextual verification, and failure to establish direct relevance to the appellant's transaction. Without substantive evidence challenging the declared transaction value, the tribunal set aside the order for redemption fine and penalties, effectively upholding the appellant's original transaction value declaration for imported iron screws from China.
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