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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Rejection of declared transaction value is warranted where a portion of consideration is paid outside banking channels, vitiating the invoice price and permitting valuation under the residual method by adding undeclared consideration; consequence: assessable value increased. Deliberate non-disclosure of consideration constitutes willful misstatement and suppression, justifying invocation of the extended limitation period and assessment of differential duty with statutory interest. Admissions and enforcement agency findings permit corroborative use of such material. Deliberate undervaluation attracts mandatory penalty for collusion or suppression, quantified to include interest, and mis-declaration exposing goods to confiscation with no redemption where goods are unavailable.
Rejection of declared transaction value is warranted where a portion of consideration is paid outside banking channels, vitiating the invoice price and permitting valuation under the residual method by adding undeclared consideration; consequence: assessable value increased. Deliberate non-disclosure of consideration constitutes willful misstatement and suppression, justifying invocation of the extended limitation period and assessment of differential duty with statutory interest. Admissions and enforcement agency findings permit corroborative use of such material. Deliberate undervaluation attracts mandatory penalty for collusion or suppression, quantified to include interest, and mis-declaration exposing goods to confiscation with no redemption where goods are unavailable.
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