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 affirmed the adjudication that imported CNG kits/components qualified as packaged goods within the scope of Section 4A read with the SWM Act and Rules, requiring declaration of Retail Sale Price (RSP); consequent customs duty shortfall based on non-declaration of RSP was upheld and recovery directed for the normal assessment period. The penalty under Section 114A was quashed. Personal liability under Section 112 was sustained against the director for failure to declare RSP, but personal penalties against the officer-in-charge and the CHA were set aside. The impugned order was otherwise affirmed and the appeal disposed of accordingly.
CESTAT affirmed the adjudication that imported CNG kits/components qualified as packaged goods within the scope of Section 4A read with the SWM Act and Rules, requiring declaration of Retail Sale Price (RSP); consequent customs duty shortfall based on non-declaration of RSP was upheld and recovery directed for the normal assessment period. The penalty under Section 114A was quashed. Personal liability under Section 112 was sustained against the director for failure to declare RSP, but personal penalties against the officer-in-charge and the CHA were set aside. The impugned order was otherwise affirmed and the appeal disposed of accordingly.
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