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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Classification of imported metal turned on whether material constituted usable alloy steel or waste and scrap; authorities disregarded controlling section and chapter notes defining waste and scrap and revalued goods despite absence of reliable departmental evidence that goods were usable as prime material. The appellate reasoning rested primarily on a chartered engineer's composition finding while ignoring the engineer's categorical conclusion that the items could not serve their original specifications and were fit only for scrap. As a result the reclassification and revaluation were held unsustainable and the impugned order was set aside with appeals allowed and consequential relief granted as per law.
Classification of imported metal turned on whether material constituted usable alloy steel or waste and scrap; authorities disregarded controlling section and chapter notes defining waste and scrap and revalued goods despite absence of reliable departmental evidence that goods were usable as prime material. The appellate reasoning rested primarily on a chartered engineer's composition finding while ignoring the engineer's categorical conclusion that the items could not serve their original specifications and were fit only for scrap. As a result the reclassification and revaluation were held unsustainable and the impugned order was set aside with appeals allowed and consequential relief granted as per law.
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