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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Amendment of the Import General Manifest in respect of all four bills of lading was accepted, and the court ordered conditional clearance of 200.58 MT of copper wire rod to the owner subject to payment of basic customs duty under protest. The owner must also deposit an amount equal to interest on the basic customs duty as a deposit; that deposit may be contested in the respondents proposed appeal and will be refunded if that appeal succeeds. No interest is payable on the IGST component per precedent. The order expressly preserves liability and rights of all other noticees and does not decide merits of confiscation.
Amendment of the Import General Manifest in respect of all four bills of lading was accepted, and the court ordered conditional clearance of 200.58 MT of copper wire rod to the owner subject to payment of basic customs duty under protest. The owner must also deposit an amount equal to interest on the basic customs duty as a deposit; that deposit may be contested in the respondents proposed appeal and will be refunded if that appeal succeeds. No interest is payable on the IGST component per precedent. The order expressly preserves liability and rights of all other noticees and does not decide merits of confiscation.
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