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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CBIC instructions prescribing a monetary threshold for instituting appeals were applied to bar lowvalue Revenue appeals. The Board, exercising powers under the Customs statute, fixed a Rs.50 lakh threshold and excluded categories not matching the present disputes; because the departmental demand reduced to Rs.20,85,698, the appeals fell below the prescribed limit and were held nonmaintainable under the Government's litigation policy. Consequentially, the Revenue's appeals were dismissed for noncompliance with the CBIC instruction prescribing the monetary limit, with no substantive adjudication on merits.
CBIC instructions prescribing a monetary threshold for instituting appeals were applied to bar lowvalue Revenue appeals. The Board, exercising powers under the Customs statute, fixed a Rs.50 lakh threshold and excluded categories not matching the present disputes; because the departmental demand reduced to Rs.20,85,698, the appeals fell below the prescribed limit and were held nonmaintainable under the Government's litigation policy. Consequentially, the Revenue's appeals were dismissed for noncompliance with the CBIC instruction prescribing the monetary limit, with no substantive adjudication on merits.
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