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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
CESTAT upheld the Commissioner's rejection of the declared transaction value under Valuation Rule 12 as based on reasonable doubt, ordered sequential re-determination under Valuation Rules 3-9 with reliance on the recovered invoice data, but set aside the Commissioner's addition under Valuation Rule 10(2) (freight/insurance) because the records did not prove FOB pricing and the imported values were to be treated as CIF. Section 138C certification was not requisite for reliance on the printed Excel material in these circumstances. The confirmed duties are to be recomputed accordingly; penalty under s.114A must be recalculated, while the s.114AA penalty (Rs.50,00,000) was sustained as not excessive. Appeal allowed in part.
CESTAT upheld the Commissioner's rejection of the declared transaction value under Valuation Rule 12 as based on reasonable doubt, ordered sequential re-determination under Valuation Rules 3-9 with reliance on the recovered invoice data, but set aside the Commissioner's addition under Valuation Rule 10(2) (freight/insurance) because the records did not prove FOB pricing and the imported values were to be treated as CIF. Section 138C certification was not requisite for reliance on the printed Excel material in these circumstances. The confirmed duties are to be recomputed accordingly; penalty under s.114A must be recalculated, while the s.114AA penalty (Rs.50,00,000) was sustained as not excessive. Appeal allowed in part.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
