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 order addressing classification of Rubber Process Oil (RPO) and customs duty implications. The Tribunal found the original order legally unsustainable due to lack of specific chemical test evidence and improper rejection of in-house test reports. The key determination hinged on aromatic constituent percentages for tariff classification. The impugned order invoking extended limitation period under Section 28(4) of Customs Act was set aside. The Tribunal partially allowed the appeal, directing re-examination of RPO classification based on aromatic content, with differential duty demands upheld where appellants previously accepted classification under CTI 2713 9000. The decision emphasizes procedural fairness and evidentiary requirements in customs classification disputes.
CESTAT order addressing classification of Rubber Process Oil (RPO) and customs duty implications. The Tribunal found the original order legally unsustainable due to lack of specific chemical test evidence and improper rejection of in-house test reports. The key determination hinged on aromatic constituent percentages for tariff classification. The impugned order invoking extended limitation period under Section 28(4) of Customs Act was set aside. The Tribunal partially allowed the appeal, directing re-examination of RPO classification based on aromatic content, with differential duty demands upheld where appellants previously accepted classification under CTI 2713 9000. The decision emphasizes procedural fairness and evidentiary requirements in customs classification disputes.
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