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...
Knowing facilitation of diversion of duty-free imported goods from premises specified in Advance Authorisation conditions attracted penalty under Section 112(b) of the Customs Act. The Tribunal noted that the importer admitted diversion and partial duty payment, and that sales tax delivery notes handed to the appellant, including a copy given to the truck driver, showed awareness that the goods were being moved for sale contrary to the authorisation terms. On these facts, the goods were liable to confiscation and the appellant's aiding and abetting of their transport to unauthorised premises justified the penalty.
Knowing facilitation of diversion of duty-free imported goods from premises specified in Advance Authorisation conditions attracted penalty under Section 112(b) of the Customs Act. The Tribunal noted that the importer admitted diversion and partial duty payment, and that sales tax delivery notes handed to the appellant, including a copy given to the truck driver, showed awareness that the goods were being moved for sale contrary to the authorisation terms. On these facts, the goods were liable to confiscation and the appellant's aiding and abetting of their transport to unauthorised premises justified the penalty.
Note: It is a system-generated summary and is for quick reference only.