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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The text addresses valuation of exports under FOB principles, holding that FOB includes costs incurred up to loading (factory price, inland transport, packing, loading, commission/commission-like fees) and that deductions for protective-agent commissions affect export duty calculation. It treats customs settlement and deposit as admissible admissions by conduct bearing evidential weight. The piece states directors can be held liable for company contraventions absent evidence of due diligence or lack of knowledge, observing the civil penalty regime does not require mens rea. It also notes a proviso permitting adjudication beyond the target period provided reasons for delay are periodically recorded and considered.
The text addresses valuation of exports under FOB principles, holding that FOB includes costs incurred up to loading (factory price, inland transport, packing, loading, commission/commission-like fees) and that deductions for protective-agent commissions affect export duty calculation. It treats customs settlement and deposit as admissible admissions by conduct bearing evidential weight. The piece states directors can be held liable for company contraventions absent evidence of due diligence or lack of knowledge, observing the civil penalty regime does not require mens rea. It also notes a proviso permitting adjudication beyond the target period provided reasons for delay are periodically recorded and considered.
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