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 imported natural rubber latex under tariff headings must follow the General Rules for Interpretation; where headings and notes permit divergent legal interpretation, revenue bears the burden to prove misclassification. Post-clearance audit and ACP/AEO facilitation require authorities to produce cogent evidence before alleging misconduct; wilful misstatement demands proof of a positive act and intent. Because the departmental challenge could reflect a genuine divergence of view and no negative intention was established, the show-cause notice was held time-barred and the impugned demand was set aside, with consequential relief permitted.
Classification of imported natural rubber latex under tariff headings must follow the General Rules for Interpretation; where headings and notes permit divergent legal interpretation, revenue bears the burden to prove misclassification. Post-clearance audit and ACP/AEO facilitation require authorities to produce cogent evidence before alleging misconduct; wilful misstatement demands proof of a positive act and intent. Because the departmental challenge could reflect a genuine divergence of view and no negative intention was established, the show-cause notice was held time-barred and the impugned demand was set aside, with consequential relief permitted.
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