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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The Supreme Court dismissed the appeal filed by the appellant Revenue, challenging the confiscation and penalty imposed for alleged violation of exemption conditions under notification N/N. 146/94-Cus. The issue concerned the sale of imported arms and ammunition to State Rifle Associations and District Clubs rather than direct use in national or international competitions. The tribunal had held that the exemption did not impose an "Actual User" condition and that the goods were used for the intended purpose. The Court concurred with this finding, concluding that no violation of the exemption conditions occurred. Consequently, the appeal was dismissed for lack of merit, affirming the tribunal's decision and upholding the legality of the impugned order.
The Supreme Court dismissed the appeal filed by the appellant Revenue, challenging the confiscation and penalty imposed for alleged violation of exemption conditions under notification N/N. 146/94-Cus. The issue concerned the sale of imported arms and ammunition to State Rifle Associations and District Clubs rather than direct use in national or international competitions. The tribunal had held that the exemption did not impose an "Actual User" condition and that the goods were used for the intended purpose. The Court concurred with this finding, concluding that no violation of the exemption conditions occurred. Consequently, the appeal was dismissed for lack of merit, affirming the tribunal's decision and upholding the legality of the impugned order.
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