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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Allegations of undervaluation and misdeclaration of imported LED TVs as unbranded were rejected because the panchnama showed brand stickers only on certain LED panels while other parts lacked branding, and branding of a component could not legally convert the entire TV into a branded product; hence rejection of declared value on this ground was unsustainable. Reliance on computer printouts/retrieved data was inadmissible as the mandatory conditions for electronic evidence under Section 138C were not complied with, leaving the allegations unproved; consequently, re-determination of value was set aside. For drywall screws, absence of contemporaneous examination and comparison with invoices from different financial years and unrelated parties rendered the valuation exercise presumptive; therefore, revaluation was quashed and the appeal was allowed. - CESTAT
Allegations of undervaluation and misdeclaration of imported LED TVs as unbranded were rejected because the panchnama showed brand stickers only on certain LED panels while other parts lacked branding, and branding of a component could not legally convert the entire TV into a branded product; hence rejection of declared value on this ground was unsustainable. Reliance on computer printouts/retrieved data was inadmissible as the mandatory conditions for electronic evidence under Section 138C were not complied with, leaving the allegations unproved; consequently, re-determination of value was set aside. For drywall screws, absence of contemporaneous examination and comparison with invoices from different financial years and unrelated parties rendered the valuation exercise presumptive; therefore, revaluation was quashed and the appeal was allowed. - CESTAT
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