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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The HC held that the Fe content in imported iron ore fines (IOF) must be determined based on wet metric tonnage (WMT) rather than dry metric tonnage (DMT), reaffirming the precedent set by a coordinate bench. The court emphasized the principle of judicial discipline requiring adherence to prior decisions of coordinate benches unless a larger bench is constituted. Consequently, the appellant's contention challenging the established method was rejected. The court found no substantial question of law under Section 130 of the Customs Act, 1962, arising from the appeals. Accordingly, the appeals were dismissed, upholding the revenue's position and maintaining uniformity in the legal interpretation concerning customs duty assessment on IOF consignments.
The HC held that the Fe content in imported iron ore fines (IOF) must be determined based on wet metric tonnage (WMT) rather than dry metric tonnage (DMT), reaffirming the precedent set by a coordinate bench. The court emphasized the principle of judicial discipline requiring adherence to prior decisions of coordinate benches unless a larger bench is constituted. Consequently, the appellant's contention challenging the established method was rejected. The court found no substantial question of law under Section 130 of the Customs Act, 1962, arising from the appeals. Accordingly, the appeals were dismissed, upholding the revenue's position and maintaining uniformity in the legal interpretation concerning customs duty assessment on IOF consignments.
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