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 appellant's appeal, upholding the impugned order which included costs incurred to render the wrecked vessel marketable in the assessable value for customs duty. The Tribunal found the sale was on an "as is where is" basis off Oyster Rock, placing responsibility on the purchaser to effect removal, break-up and clearance; consequently costs of bringing the wreck into smaller pieces and associated handling were correctly added to the invoice value. The appellant did not contest the quantum of the added charges before the adjudicating authority or the Tribunal, which were substantiated by the appellant's own books. No infirmity in the valuation determination was found and the appeal was dismissed.
CESTAT dismissed the appellant's appeal, upholding the impugned order which included costs incurred to render the wrecked vessel marketable in the assessable value for customs duty. The Tribunal found the sale was on an "as is where is" basis off Oyster Rock, placing responsibility on the purchaser to effect removal, break-up and clearance; consequently costs of bringing the wreck into smaller pieces and associated handling were correctly added to the invoice value. The appellant did not contest the quantum of the added charges before the adjudicating authority or the Tribunal, which were substantiated by the appellant's own books. No infirmity in the valuation determination was found and the appeal was dismissed.
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