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 appeal, setting aside the revocation of authorized carrier registration and imposed penalties. The tribunal found that the appellant did not violate Regulation 10(1)(l) and 10(1)(m) of SCMTR, 2018. The adjudicating authority's findings were deemed incorrect, as the appellant appeared to have acted in compliance with the regulatory framework. The tribunal concluded that the detention periods and additional delays did not constitute substantive regulatory violations warranting punitive action against the authorized carrier, thus restoring the carrier's registration status.
CESTAT allowed the appeal, setting aside the revocation of authorized carrier registration and imposed penalties. The tribunal found that the appellant did not violate Regulation 10(1)(l) and 10(1)(m) of SCMTR, 2018. The adjudicating authority's findings were deemed incorrect, as the appellant appeared to have acted in compliance with the regulatory framework. The tribunal concluded that the detention periods and additional delays did not constitute substantive regulatory violations warranting punitive action against the authorized carrier, thus restoring the carrier's registration status.
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