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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Rutile ore/rutile sand imported under Chapter 26 was held to remain ore where only normal physical preparation was shown; conversion into concentrate requires proof of special beneficiation or treatment affecting composition, which was absent on the record. The descriptions in the Bills of Entry, invoices and supplier certificates matched the departmental test results, so the misdeclaration allegation failed and no wilful suppression justified the extended period. Because the imports were accepted as ores, denial of exemption from additional duty under the cited notifications also failed. Confiscation and penalty were unsustainable for want of proved misstatement or intent to evade duty.
Rutile ore/rutile sand imported under Chapter 26 was held to remain ore where only normal physical preparation was shown; conversion into concentrate requires proof of special beneficiation or treatment affecting composition, which was absent on the record. The descriptions in the Bills of Entry, invoices and supplier certificates matched the departmental test results, so the misdeclaration allegation failed and no wilful suppression justified the extended period. Because the imports were accepted as ores, denial of exemption from additional duty under the cited notifications also failed. Confiscation and penalty were unsustainable for want of proved misstatement or intent to evade duty.
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