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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Freezing of a bank account under section 110(5) of the Customs Act may initially continue for six months and be extended once for a further six months only on recorded written reasons. Issuance of a show-cause notice does not preserve investigating authorities' power to continue the freeze beyond the statutory maximum of twelve months. As the maximum period had expired, the High Court found a prima facie basis for de-freezing and directed the bank to de-freeze the account forthwith.
Freezing of a bank account under section 110(5) of the Customs Act may initially continue for six months and be extended once for a further six months only on recorded written reasons. Issuance of a show-cause notice does not preserve investigating authorities' power to continue the freeze beyond the statutory maximum of twelve months. As the maximum period had expired, the High Court found a prima facie basis for de-freezing and directed the bank to de-freeze the account forthwith.
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