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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Concessional rate of basic customs duty reassessment was challenged on grounds that ICES-derived information used by the appellate authority was not disclosed to the importer, breaching natural justice; consequence: impugned order set aside for failure to furnish material and opportunity. The absence of a separate speaking order when re-assessment findings were applied across multiple imports rendered the appellate exercise inappropriate; consequence: appellate treatment declared collateral adjudication and unreliable. Confiscation and penalty powers were referenced but not permitted to validate the defective appellate process; consequence: all 50 appeals restored to first appellate authority for fresh consideration on merit and maintainability.
Concessional rate of basic customs duty reassessment was challenged on grounds that ICES-derived information used by the appellate authority was not disclosed to the importer, breaching natural justice; consequence: impugned order set aside for failure to furnish material and opportunity. The absence of a separate speaking order when re-assessment findings were applied across multiple imports rendered the appellate exercise inappropriate; consequence: appellate treatment declared collateral adjudication and unreliable. Confiscation and penalty powers were referenced but not permitted to validate the defective appellate process; consequence: all 50 appeals restored to first appellate authority for fresh consideration on merit and maintainability.
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