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(5) limits provisional attachment of bank accounts under customs law to six months, with one recorded-reasons extension of up to six months. A debit freeze continuing beyond one year, after investigation culminates in adjudication, lacks statutory support. Where an appeal against the adjudication order is filed with the mandatory pre-deposit, continued freezing is coercive and unlawful; the affected bank accounts must be defreezed.
Section 110(5) limits provisional attachment of bank accounts under customs law to six months, with one recorded-reasons extension of up to six months. A debit freeze continuing beyond one year, after investigation culminates in adjudication, lacks statutory support. Where an appeal against the adjudication order is filed with the mandatory pre-deposit, continued freezing is coercive and unlawful; the affected bank accounts must be defreezed.
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