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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Appellate recourse remained available where a superior officer had assumed functions ordinarily exercised by the proper officer, because such assumption did not extinguish the normal appeal mechanism. The Tribunal further held that the imported goods were not shown to fall within the Steel and Steel Products (Quality Control) Order, 2020 entries requiring BIS certification, so confiscation under section 111(d) for breach of import prohibition could not stand. Misdescription was also not established, as the goods remained classifiable under the same tariff item and the record did not prove intent to evade duty. The declared transaction value could not be rejected without a lawful rule 12 basis and sequential valuation under the valuation rules, so enhancement was unsustainable.
Appellate recourse remained available where a superior officer had assumed functions ordinarily exercised by the proper officer, because such assumption did not extinguish the normal appeal mechanism. The Tribunal further held that the imported goods were not shown to fall within the Steel and Steel Products (Quality Control) Order, 2020 entries requiring BIS certification, so confiscation under section 111(d) for breach of import prohibition could not stand. Misdescription was also not established, as the goods remained classifiable under the same tariff item and the record did not prove intent to evade duty. The declared transaction value could not be rejected without a lawful rule 12 basis and sequential valuation under the valuation rules, so enhancement was unsustainable.
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