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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Re-determination of assessable value under Rule 7 of the Customs Valuation Rules was held invalid because the market survey lacked contemporaneous, comparable import data and did not demonstrate identical or similar goods at the same commercial level, so valuation based solely on median domestic invoices was set aside. Classification was resolved by applying the General Rules for Interpretation: articles whose principal function is as an assistive walking-stick retain classification under CTI 6602 0000 despite an ancillary torch, and the appellants' classification was upheld. Consequential confiscation, redemption fine and penalties were quashed as unsustainable where declarations were not materially false and labelling could be complied with before clearance.
Re-determination of assessable value under Rule 7 of the Customs Valuation Rules was held invalid because the market survey lacked contemporaneous, comparable import data and did not demonstrate identical or similar goods at the same commercial level, so valuation based solely on median domestic invoices was set aside. Classification was resolved by applying the General Rules for Interpretation: articles whose principal function is as an assistive walking-stick retain classification under CTI 6602 0000 despite an ancillary torch, and the appellants' classification was upheld. Consequential confiscation, redemption fine and penalties were quashed as unsustainable where declarations were not materially false and labelling could be complied with before clearance.
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