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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
CESTAT treated the threshold question as one of jurisdiction: whether customs authorities and the Tribunal can determine disputes involving interpretation of IGST rate schedules on imports, given the separate appellate framework under the GST enactments. Noting conflicting views on the issue and examining the Customs Act, Customs Tariff Act and IGST Act scheme, the Tribunal held that the jurisdictional conflict required authoritative resolution before any merits review. It therefore referred the formulated questions to the President for constitution of a Larger Bench and left the classification and rate dispute open.
CESTAT treated the threshold question as one of jurisdiction: whether customs authorities and the Tribunal can determine disputes involving interpretation of IGST rate schedules on imports, given the separate appellate framework under the GST enactments. Noting conflicting views on the issue and examining the Customs Act, Customs Tariff Act and IGST Act scheme, the Tribunal held that the jurisdictional conflict required authoritative resolution before any merits review. It therefore referred the formulated questions to the President for constitution of a Larger Bench and left the classification and rate dispute open.
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