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 appellate order involving misdeclaration of imported goods classified as "China Glass Imitation Stone". The tribunal rejected appellant's challenge to valuation and penalty, finding substantial evidence of intentional undervaluation. Despite appellant's request for cross-examination, the tribunal determined that no procedural prejudice occurred, as the appellant's own statements implicated his involvement in the import irregularities. The original authority's valuation methodology using contemporaneous import data was deemed appropriate. The tribunal upheld the original order, imposing penalties under Sections 112(b) and 114AA, and consequently dismissed the appeals against the demand notices. The decision affirmed the comprehensive evidentiary chain establishing the appellant's direct participation in the misdeclaration scheme.
CESTAT appellate order involving misdeclaration of imported goods classified as "China Glass Imitation Stone". The tribunal rejected appellant's challenge to valuation and penalty, finding substantial evidence of intentional undervaluation. Despite appellant's request for cross-examination, the tribunal determined that no procedural prejudice occurred, as the appellant's own statements implicated his involvement in the import irregularities. The original authority's valuation methodology using contemporaneous import data was deemed appropriate. The tribunal upheld the original order, imposing penalties under Sections 112(b) and 114AA, and consequently dismissed the appeals against the demand notices. The decision affirmed the comprehensive evidentiary chain establishing the appellant's direct participation in the misdeclaration scheme.
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