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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Provisional release of imported used highly specialized digital multifunction print/copying machines, though treated as restricted goods, was ordered because the importer had already executed a provisional duty bond and furnished a bank guarantee covering the assessable value of the entire consignment, leaving no justification to withhold release of the remaining 63 units. The Tribunal relied on the absence of any demonstrated shortfall in security and directed release subject to the same conditions earlier upheld in analogous litigation requiring bond and bank guarantee pending adjudication, thereby ensuring revenue protection while permitting release. - CESTAT
Provisional release of imported used highly specialized digital multifunction print/copying machines, though treated as restricted goods, was ordered because the importer had already executed a provisional duty bond and furnished a bank guarantee covering the assessable value of the entire consignment, leaving no justification to withhold release of the remaining 63 units. The Tribunal relied on the absence of any demonstrated shortfall in security and directed release subject to the same conditions earlier upheld in analogous litigation requiring bond and bank guarantee pending adjudication, thereby ensuring revenue protection while permitting release. - CESTAT
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