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 dismissed the Revenue's appeal challenging redetermination of value for imported metal scrap under Rule 12 of Customs Valuation Rules, 2007 and Section 14 of Customs Act, 1962. The department relied on a Tribunal precedent from Commissioner of Customs, Patparganj vs. Hanuman Prasad & Sons case. However, Delhi HC recently overruled this Tribunal decision in Niraj Silk Mills case, ruling in favor of the importer after examining various Tribunal and Supreme Court judgments on identical valuation issues. CESTAT found no infirmity in the Commissioner (Appeals) order rejecting value enhancement, upholding the importer's position on customs valuation determination.
CESTAT dismissed the Revenue's appeal challenging redetermination of value for imported metal scrap under Rule 12 of Customs Valuation Rules, 2007 and Section 14 of Customs Act, 1962. The department relied on a Tribunal precedent from Commissioner of Customs, Patparganj vs. Hanuman Prasad & Sons case. However, Delhi HC recently overruled this Tribunal decision in Niraj Silk Mills case, ruling in favor of the importer after examining various Tribunal and Supreme Court judgments on identical valuation issues. CESTAT found no infirmity in the Commissioner (Appeals) order rejecting value enhancement, upholding the importer's position on customs valuation determination.
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