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 importer's appeal against the Commissioner's order enhancing the declared value of imported motorcycle batteries. It upheld the rejection of the transaction value, noting documentary evidence demonstrating that the declared price was substantially lower than contemporaneous international market prices for similar goods. The Tribunal held that the Commissioner rightly proceeded ex parte after the appellant failed to file any reply to the SCN or contest the documentary evidence. A belated request for adjournment at the dictation stage was rejected. Finding no illegality or infirmity, the impugned order was affirmed.
CESTAT dismissed the importer's appeal against the Commissioner's order enhancing the declared value of imported motorcycle batteries. It upheld the rejection of the transaction value, noting documentary evidence demonstrating that the declared price was substantially lower than contemporaneous international market prices for similar goods. The Tribunal held that the Commissioner rightly proceeded ex parte after the appellant failed to file any reply to the SCN or contest the documentary evidence. A belated request for adjournment at the dictation stage was rejected. Finding no illegality or infirmity, the impugned order was affirmed.
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