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 customs dispute regarding imported dry dates' country of origin. The tribunal determined that packing material and circumstantial evidence cannot conclusively establish goods' origin. Documentary evidence including Certificate of Origin from Dubai Chamber of Commerce & Industry, Bill of Lading, and commercial invoices substantiated United Arab Emirates as the legitimate country of origin. The tribunal rejected re-assessment findings proposing Pakistan origin, finding insufficient documentary proof. Consequently, the original assessment order was set aside, and the importer's appeal was allowed, emphasizing that packaging materials alone cannot definitively determine product origin.
CESTAT adjudicated a customs dispute regarding imported dry dates' country of origin. The tribunal determined that packing material and circumstantial evidence cannot conclusively establish goods' origin. Documentary evidence including Certificate of Origin from Dubai Chamber of Commerce & Industry, Bill of Lading, and commercial invoices substantiated United Arab Emirates as the legitimate country of origin. The tribunal rejected re-assessment findings proposing Pakistan origin, finding insufficient documentary proof. Consequently, the original assessment order was set aside, and the importer's appeal was allowed, emphasizing that packaging materials alone cannot definitively determine product origin.
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