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...
Customs Broker licence revocation requires a serious breach of primary regulatory obligations; address-change and Customs Station intimation failures, and signature-related irregularities, are procedural contraventions warranting penalty rather than revocation or security forfeiture. Electronic processing through ICEGATE means same-day clearances at multiple ports do not, without supporting evidence, prove licence subletting. Client due diligence does not require physical verification of premises, and undisclosed DRI notices cannot be inferred without proof of receipt. A Customs Broker's compliance-advice duty is limited to documents handled at entry or departure and does not extend to exporters' downstream excess RoSL claims. Licence revocation and security forfeiture were set aside, while procedural penalties were maintained or reduced.
Customs Broker licence revocation requires a serious breach of primary regulatory obligations; address-change and Customs Station intimation failures, and signature-related irregularities, are procedural contraventions warranting penalty rather than revocation or security forfeiture. Electronic processing through ICEGATE means same-day clearances at multiple ports do not, without supporting evidence, prove licence subletting. Client due diligence does not require physical verification of premises, and undisclosed DRI notices cannot be inferred without proof of receipt. A Customs Broker's compliance-advice duty is limited to documents handled at entry or departure and does not extend to exporters' downstream excess RoSL claims. Licence revocation and security forfeiture were set aside, while procedural penalties were maintained or reduced.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
