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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Reassessment of assessable value based solely on an empanelled Chartered Engineer certificate was held impermissible where the sequential valuation steps under the Customs Valuation Rules, 2007 and adequate market evidence were not followed; the enhanced value was set aside and the declared value accepted. Imports of restricted MFD parts were not subject to absolute confiscation where authorisation was lacking; redemption was allowed with a fine fixed at 10% and a penalty fixed at 5% of the assessable value. Earlier precedent rejecting engineer-certificate-only enhancement and permitting redemption governed the outcome.
Reassessment of assessable value based solely on an empanelled Chartered Engineer certificate was held impermissible where the sequential valuation steps under the Customs Valuation Rules, 2007 and adequate market evidence were not followed; the enhanced value was set aside and the declared value accepted. Imports of restricted MFD parts were not subject to absolute confiscation where authorisation was lacking; redemption was allowed with a fine fixed at 10% and a penalty fixed at 5% of the assessable value. Earlier precedent rejecting engineer-certificate-only enhancement and permitting redemption governed the outcome.
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