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...
Discretionary writ jurisdiction requires a prompt approach and full disclosure of material facts. Unexplained delay, omission of the contemporaneous Customs Act statement, and disputes over whether detained yellow metal jewellery constituted a personal effect, its value, and compliance with baggage requirements prevented unconditional release or quashing of detention. Appraisement and statutory proceedings must instead be completed by the competent authority in accordance with law, preferably within three months subject to the claimant's cooperation. The writ petition was dismissed without determining confiscation, duty, fine, penalty, or waiver of warehouse and handling charges, which remain within the statutory process.
Discretionary writ jurisdiction requires a prompt approach and full disclosure of material facts. Unexplained delay, omission of the contemporaneous Customs Act statement, and disputes over whether detained yellow metal jewellery constituted a personal effect, its value, and compliance with baggage requirements prevented unconditional release or quashing of detention. Appraisement and statutory proceedings must instead be completed by the competent authority in accordance with law, preferably within three months subject to the claimant's cooperation. The writ petition was dismissed without determining confiscation, duty, fine, penalty, or waiver of warehouse and handling charges, which remain within the statutory process.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
