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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Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
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