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 appeals challenging customs broker license revocation. The tribunal found procedural irregularities in successive orders passed within three weeks, determining that licensing authority acted mechanically without proper legal basis. The court observed no substantive evidence establishing violations of regulatory provisions, and critically noted the authorities' casual handling of license matters undermined regulatory implementation. Consequently, the impugned orders were set aside, effectively reinstating the customs broker's license and rejecting security deposit forfeiture and penalty imposition.
CESTAT allowed appeals challenging customs broker license revocation. The tribunal found procedural irregularities in successive orders passed within three weeks, determining that licensing authority acted mechanically without proper legal basis. The court observed no substantive evidence establishing violations of regulatory provisions, and critically noted the authorities' casual handling of license matters undermined regulatory implementation. Consequently, the impugned orders were set aside, effectively reinstating the customs broker's license and rejecting security deposit forfeiture and penalty imposition.
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