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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Classification of ores versus concentrates: processing of Run of Mine ore through screening, sizing and crushing resulting in concentrates is treated as manufacture; the transformed material qualifies as distinct excisable goods in light of chapter notes, HSN explanations and deeming provisions, with the consequence that exemption claimed under the relevant notification is not available. Strict construction of the exemption was applied, leading to recovery of differential duty. Delay in payment of duty attracts statutory interest, which is payable alongside the recovered duty.
Classification of ores versus concentrates: processing of Run of Mine ore through screening, sizing and crushing resulting in concentrates is treated as manufacture; the transformed material qualifies as distinct excisable goods in light of chapter notes, HSN explanations and deeming provisions, with the consequence that exemption claimed under the relevant notification is not available. Strict construction of the exemption was applied, leading to recovery of differential duty. Delay in payment of duty attracts statutory interest, which is payable alongside the recovered duty.
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