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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Redetermination of transaction value and consequential duty demand/penalties on imported goods declared as processed coral waste was held unsustainable because the Department led no independent evidence to justify rejection of the declared invoice value or to support undervaluation, and did not rebut supplier invoices and declarations certifying description and value. Applying the principle that invoice value cannot be rejected arbitrarily without valid reasons, contemporaneous comparable import data, or other credible evidence, and noting that customs examination did not dispute the nature of goods, the demand and penalties were set aside and the appeal was allowed - CESTAT
Redetermination of transaction value and consequential duty demand/penalties on imported goods declared as processed coral waste was held unsustainable because the Department led no independent evidence to justify rejection of the declared invoice value or to support undervaluation, and did not rebut supplier invoices and declarations certifying description and value. Applying the principle that invoice value cannot be rejected arbitrarily without valid reasons, contemporaneous comparable import data, or other credible evidence, and noting that customs examination did not dispute the nature of goods, the demand and penalties were set aside and the appeal was allowed - CESTAT
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