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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HC examined rebate entitlement for exported goods, focusing on valuation methodology. The Revisional Authority's interpretation of excise duty assessment was found incorrect. The court determined that the adjudicating authority exceeded jurisdictional limits by re-examining assessment during rebate claim processing. For a merchant exporter without Cenvat account, directions to re-credit duties were deemed inappropriate. The Revisional Authority's order relied on an inapplicable precedent and misinterpreted valuation rules. Consequently, the HC quashed the impugned order, holding that the original rebate claim should be processed based on the submitted documentation without additional assessment scrutiny.
HC examined rebate entitlement for exported goods, focusing on valuation methodology. The Revisional Authority's interpretation of excise duty assessment was found incorrect. The court determined that the adjudicating authority exceeded jurisdictional limits by re-examining assessment during rebate claim processing. For a merchant exporter without Cenvat account, directions to re-credit duties were deemed inappropriate. The Revisional Authority's order relied on an inapplicable precedent and misinterpreted valuation rules. Consequently, the HC quashed the impugned order, holding that the original rebate claim should be processed based on the submitted documentation without additional assessment scrutiny.
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