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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CESTAT addressed classification and valuation of imported controllers, applying the principal use rule, Notes to Section XVII and explanatory notes to conclude the controllers constitute electrical machinery classifiable under Chapter 85 rather than motor vehicle parts under Chapter 87; consequence: classification under Chapter 85 was upheld and the declared transaction value and assessable value treatment accepted. Note 2(f) to Section XVII excluding electrical machinery from Chapter 87 was determinative. The Tribunal followed earlier final orders in the appellants cases as precedent, resulting in dismissal of the revenue appeals.
CESTAT addressed classification and valuation of imported controllers, applying the principal use rule, Notes to Section XVII and explanatory notes to conclude the controllers constitute electrical machinery classifiable under Chapter 85 rather than motor vehicle parts under Chapter 87; consequence: classification under Chapter 85 was upheld and the declared transaction value and assessable value treatment accepted. Note 2(f) to Section XVII excluding electrical machinery from Chapter 87 was determinative. The Tribunal followed earlier final orders in the appellants cases as precedent, resulting in dismissal of the revenue appeals.
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