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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Section 110(1) customs seizure requires a reason to believe, based on relevant material, that goods are liable to confiscation under Section 111; mere suspicion is insufficient. In the areca nuts matter, the record contained tax invoices, GST payment details and an e-way bill supporting lawful intra-State movement, while the seizure inventory and laboratory report did not show foreign origin. The seizure of the goods and truck was therefore without jurisdiction, and release was directed unless fresh material later emerged.
Section 110(1) customs seizure requires a reason to believe, based on relevant material, that goods are liable to confiscation under Section 111; mere suspicion is insufficient. In the areca nuts matter, the record contained tax invoices, GST payment details and an e-way bill supporting lawful intra-State movement, while the seizure inventory and laboratory report did not show foreign origin. The seizure of the goods and truck was therefore without jurisdiction, and release was directed unless fresh material later emerged.
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