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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Modular kitchen components imported in CKD/SKD condition are classifiable as furniture under Chapter 94 determined at the time and condition of importation, but that classification does not displace the statutory valuation regime: administrative DGOV furniture valuation guidelines cannot override Section 14 or the sequence of the Customs Valuation Rules. Rejection of transaction value and revaluation under Rule 12 and Rule 4 must use truly comparable goods at the same commercial level and substantially the same quantity; a mechanical per kilogram partitioning of invoice value failed the comparability requirement and lacked proof that the parties' relationship influenced price, so enhancement for 11 consignments was set aside while remaining declared values were accepted under Rule 3(3)(a).
Modular kitchen components imported in CKD/SKD condition are classifiable as furniture under Chapter 94 determined at the time and condition of importation, but that classification does not displace the statutory valuation regime: administrative DGOV furniture valuation guidelines cannot override Section 14 or the sequence of the Customs Valuation Rules. Rejection of transaction value and revaluation under Rule 12 and Rule 4 must use truly comparable goods at the same commercial level and substantially the same quantity; a mechanical per kilogram partitioning of invoice value failed the comparability requirement and lacked proof that the parties' relationship influenced price, so enhancement for 11 consignments was set aside while remaining declared values were accepted under Rule 3(3)(a).
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