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...
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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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In export valuation under Section 14, the transaction value is the primary measure and Customs Valuation Rules (CVR, 2007) must be applied sequentially; the Revenue bears the burden to displace a declared invoice value. The tribunal found the department bypassed the sequential Rules and improperly relied on a market survey that compared manufacturers' prices to a trader's procurement cost, rendering the comparison and re-determined per unit valuation (with an added notional 10% profit) incorrect and unsupported by law. Because the Revenue failed to justify reassessment, the appeals were dismissed and the seized goods were directed to be released following upload of the order.
In export valuation under Section 14, the transaction value is the primary measure and Customs Valuation Rules (CVR, 2007) must be applied sequentially; the Revenue bears the burden to displace a declared invoice value. The tribunal found the department bypassed the sequential Rules and improperly relied on a market survey that compared manufacturers' prices to a trader's procurement cost, rendering the comparison and re-determined per unit valuation (with an added notional 10% profit) incorrect and unsupported by law. Because the Revenue failed to justify reassessment, the appeals were dismissed and the seized goods were directed to be released following upload of the order.
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