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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IGST exemption on imported engine stands claimed under Sr. No. 557B of Notification No. 50/2017 was remitted for fresh decision because the show cause notice itself treated the imports as lease-based and the existing bond documents were on record; the Principal Commissioner was directed to reconsider the claim after allowing the importer to file the lease agreements and supporting material. Classification of the engine stands was also remitted, as the Tribunal noted its earlier decision in Interglobe Aviation Ltd. classifying such goods under CTI 8609 00 00 rather than CTI 8716 39 00, and directed fresh examination in that light. No final merits determination was made on either issue.
IGST exemption on imported engine stands claimed under Sr. No. 557B of Notification No. 50/2017 was remitted for fresh decision because the show cause notice itself treated the imports as lease-based and the existing bond documents were on record; the Principal Commissioner was directed to reconsider the claim after allowing the importer to file the lease agreements and supporting material. Classification of the engine stands was also remitted, as the Tribunal noted its earlier decision in Interglobe Aviation Ltd. classifying such goods under CTI 8609 00 00 rather than CTI 8716 39 00, and directed fresh examination in that light. No final merits determination was made on either issue.
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