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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A ministerial certificate authorising import of a specified stainless steel grade is binding on other importers; where the Ministry has permitted import of that grade for one party, the same permission applies to others and precludes sustaining import restrictions. Customs identification of the consignment by the declared grade is dispositive for classification. Applying that ratio, the commentary concludes that challenges to redemption fine and personal penalty succeed where they rested solely on disallowing import of the certified grade, entitling affected importers to relief on those penalty aspects.
A ministerial certificate authorising import of a specified stainless steel grade is binding on other importers; where the Ministry has permitted import of that grade for one party, the same permission applies to others and precludes sustaining import restrictions. Customs identification of the consignment by the declared grade is dispositive for classification. Applying that ratio, the commentary concludes that challenges to redemption fine and personal penalty succeed where they rested solely on disallowing import of the certified grade, entitling affected importers to relief on those penalty aspects.
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