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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Changes to provisional assessment under the Customs Act introduce a two-year statutory limit for finalisation (extendable for sufficient cause), apply that limit to pending cases from 29 March 2025, and allow certain grounds to pause the limitation until reasons cease. Regulations require submission of supporting documents or test reports within 14 months (same timeframe for enquiries and transfer of records), permit finalisation on available records with natural justice, and encourage finalisation within three months after receipt of documents. Provisions cover payments during pendency, bond/security cancellation or recovery (including adjustment after 90 days where dues are final), project imports, an all-India multi-purpose bond, and monitoring of cases beyond 17 months.
Changes to provisional assessment under the Customs Act introduce a two-year statutory limit for finalisation (extendable for sufficient cause), apply that limit to pending cases from 29 March 2025, and allow certain grounds to pause the limitation until reasons cease. Regulations require submission of supporting documents or test reports within 14 months (same timeframe for enquiries and transfer of records), permit finalisation on available records with natural justice, and encourage finalisation within three months after receipt of documents. Provisions cover payments during pendency, bond/security cancellation or recovery (including adjustment after 90 days where dues are final), project imports, an all-India multi-purpose bond, and monitoring of cases beyond 17 months.
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