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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Prescribes handling of show cause notices for non-realisation or short realisation of export proceeds where scrutiny of DGFT e-BRCs indicates a shortfall against FOB value. It reiterates CBIC guidance that deductions for agency commission and foreign bank charges may be regularised on merits within an overall limit of 12.5% of FOB, subject to supporting documents such as export invoices and bank confirmation of foreign bank charges. Exporters are directed to submit proof of realisation and, where shortfall is claimed, the requisite documentary justification along with the reply to the notice. Where shortfall persists and supporting proof is not furnished with the reply, adjudication must include a personal hearing opportunity before decision.
Prescribes handling of show cause notices for non-realisation or short realisation of export proceeds where scrutiny of DGFT e-BRCs indicates a shortfall against FOB value. It reiterates CBIC guidance that deductions for agency commission and foreign bank charges may be regularised on merits within an overall limit of 12.5% of FOB, subject to supporting documents such as export invoices and bank confirmation of foreign bank charges. Exporters are directed to submit proof of realisation and, where shortfall is claimed, the requisite documentary justification along with the reply to the notice. Where shortfall persists and supporting proof is not furnished with the reply, adjudication must include a personal hearing opportunity before decision.
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