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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Rectification of customs documentation for an inadvertent typographical error in unit price was held to merit reconsideration; the petitioners' claim that invoices and purchase orders contained bona fide mistakes should be examined under the statutory rectification framework and relevant standing orders. The High Court found no adequate reason in the impugned communication to reject the case and set aside that communication, remanding the matter to the Deputy Commissioner of Customs to reconsider cancellation of out-of-charges, recall and reassessment of bills of entry, and amendment of unit price after hearing the petitioners. A decision is directed to be taken expeditiously within six weeks.
Rectification of customs documentation for an inadvertent typographical error in unit price was held to merit reconsideration; the petitioners' claim that invoices and purchase orders contained bona fide mistakes should be examined under the statutory rectification framework and relevant standing orders. The High Court found no adequate reason in the impugned communication to reject the case and set aside that communication, remanding the matter to the Deputy Commissioner of Customs to reconsider cancellation of out-of-charges, recall and reassessment of bills of entry, and amendment of unit price after hearing the petitioners. A decision is directed to be taken expeditiously within six weeks.
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