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 CESTAT upheld the classification of squid liver powder under Customs Tariff Heading 2309 9090, rejecting the appellant's contention for classification under 2301 2011. The tribunal found that reliance solely on the Chemical Examiner's report, which was not shared with the appellant, and extraneous grounds not raised in original proceedings was improper. The appellant's own supplier documentation and previous classification under 2309 9090 supported the final decision, and no prejudice was demonstrated. The appellant's inconsistent stance and fresh pleas introduced during the hearing, including the claim that the product is an attractant, were deemed inadmissible and without merit. Consequently, the appeal was dismissed with no substantive change to the classification order.
The CESTAT upheld the classification of squid liver powder under Customs Tariff Heading 2309 9090, rejecting the appellant's contention for classification under 2301 2011. The tribunal found that reliance solely on the Chemical Examiner's report, which was not shared with the appellant, and extraneous grounds not raised in original proceedings was improper. The appellant's own supplier documentation and previous classification under 2309 9090 supported the final decision, and no prejudice was demonstrated. The appellant's inconsistent stance and fresh pleas introduced during the hearing, including the claim that the product is an attractant, were deemed inadmissible and without merit. Consequently, the appeal was dismissed with no substantive change to the classification order.
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