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 appeal, upholding denial of the concessional duty rate for imported gold coins. The tribunal affirmed that the appellant failed to discharge the burden of proving entitlement under the exemption notification because the coins lacked the mandated engraved serial numbers and therefore did not satisfy the notification's unambiguous description for S.No.1 or S.No.2. Applying the principle that clear statutory language admits only its plain meaning, CESTAT found no infirmity in the reasons of the lower authorities and concluded there was no merit in the challenge to classification or exemption claim; the assessment and duty denial were consequently sustained.
CESTAT dismissed the appeal, upholding denial of the concessional duty rate for imported gold coins. The tribunal affirmed that the appellant failed to discharge the burden of proving entitlement under the exemption notification because the coins lacked the mandated engraved serial numbers and therefore did not satisfy the notification's unambiguous description for S.No.1 or S.No.2. Applying the principle that clear statutory language admits only its plain meaning, CESTAT found no infirmity in the reasons of the lower authorities and concluded there was no merit in the challenge to classification or exemption claim; the assessment and duty denial were consequently sustained.
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