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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Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
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