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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Determination of export duty hinges on validity of re-test results and reliance on laboratory reports; the tribunal accepted that a subsequent re-test produced lower Fe content (55.6%) and noted discharge port sampling at 57.2% upon which transaction value was based, concluding lower authorities properly examined factual evidence and testing competence and need not be disturbed. The decision upholds reliance on the competent laboratory re-test over earlier reports, confirms acceptance of invoice value tied to discharge port Fe content, and dismisses the revenue appeal, leaving the provisional assessment and final factual findings intact.
Determination of export duty hinges on validity of re-test results and reliance on laboratory reports; the tribunal accepted that a subsequent re-test produced lower Fe content (55.6%) and noted discharge port sampling at 57.2% upon which transaction value was based, concluding lower authorities properly examined factual evidence and testing competence and need not be disturbed. The decision upholds reliance on the competent laboratory re-test over earlier reports, confirms acceptance of invoice value tied to discharge port Fe content, and dismisses the revenue appeal, leaving the provisional assessment and final factual findings intact.
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