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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Imported goods declared as apatite calcium phosphate were held classifiable under CTI 2835 26 90, because Chapter 25 covers only natural products in crude form or products processed merely mechanically or physically, while the evidence showed calcination and chemical additions. Documentary material, including supplier emails and the importer's own conduct in seeking removal of calcination references, established deliberate misdescription; the differential duty with interest was therefore upheld. Since the goods did not match the Bills of Entry, confiscation under section 111(m) and redemption fine were sustained. Intentional misclassification to evade duty attracted penalty under section 114A, and the penalties on the director and manager were also upheld for manipulating and assisting in false customs documentation.
Imported goods declared as apatite calcium phosphate were held classifiable under CTI 2835 26 90, because Chapter 25 covers only natural products in crude form or products processed merely mechanically or physically, while the evidence showed calcination and chemical additions. Documentary material, including supplier emails and the importer's own conduct in seeking removal of calcination references, established deliberate misdescription; the differential duty with interest was therefore upheld. Since the goods did not match the Bills of Entry, confiscation under section 111(m) and redemption fine were sustained. Intentional misclassification to evade duty attracted penalty under section 114A, and the penalties on the director and manager were also upheld for manipulating and assisting in false customs documentation.
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