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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HC upheld the confiscation of imported goods under Section 111(m) CA, 1962, holding that the assessee had admitted multiple valuation errors and accepted the enhanced assessable value determined by the Department. The plea to treat design charges as separately assessable at Nil duty, based on exemption notifications for "plans, drawings and designs," was rejected as inapplicable to design charges forming part of machinery value and contrary to the assessee's earlier admissions under Rule 12. Consequently, invocation of Section 112 for penalty was sustained, with limited discretion available. All substantial questions of law were answered in favour of the revenue and against the assessee.
HC upheld the confiscation of imported goods under Section 111(m) CA, 1962, holding that the assessee had admitted multiple valuation errors and accepted the enhanced assessable value determined by the Department. The plea to treat design charges as separately assessable at Nil duty, based on exemption notifications for "plans, drawings and designs," was rejected as inapplicable to design charges forming part of machinery value and contrary to the assessee's earlier admissions under Rule 12. Consequently, invocation of Section 112 for penalty was sustained, with limited discretion available. All substantial questions of law were answered in favour of the revenue and against the assessee.
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