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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Para 5.17(a) of the HBP (FTP 2023) permits reduction of Annual Average Export Obligation (EO) for EPCG authorisations where a sector/product group records over 5% decline in exports in 2024-25 versus 2023-24; Regional Authorities must re-fix EOs accordingly and endorse reductions in licence files and amendment sheets. Regional Offices must, when considering EO discharge or shortfall actions, apply earlier policy circulars referenced and account for those precedents before issuing demand notices or EODC; this requirement must be included in the EODC check-sheet. Issued with DGFT approval.
Para 5.17(a) of the HBP (FTP 2023) permits reduction of Annual Average Export Obligation (EO) for EPCG authorisations where a sector/product group records over 5% decline in exports in 2024-25 versus 2023-24; Regional Authorities must re-fix EOs accordingly and endorse reductions in licence files and amendment sheets. Regional Offices must, when considering EO discharge or shortfall actions, apply earlier policy circulars referenced and account for those precedents before issuing demand notices or EODC; this requirement must be included in the EODC check-sheet. Issued with DGFT approval.
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