Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed.
Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed.
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