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...
Section 110(2) requires release of detained gold only if the Section 124 show-cause notice is not issued within the prescribed period, including any validly extended period. Issuance of written notice before expiry of the extended period prevents a release claim based solely on expiry of the initial period. Accordingly, no release direction follows where the petition is filed while the extended period subsists and the notice is timely issued. Questions concerning the extension's validity and communication, waiver of notice or hearing, and evidentiary value of statements remain for adjudication in accordance with law.
Section 110(2) requires release of detained gold only if the Section 124 show-cause notice is not issued within the prescribed period, including any validly extended period. Issuance of written notice before expiry of the extended period prevents a release claim based solely on expiry of the initial period. Accordingly, no release direction follows where the petition is filed while the extended period subsists and the notice is timely issued. Questions concerning the extension's validity and communication, waiver of notice or hearing, and evidentiary value of statements remain for adjudication in accordance with law.
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