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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Jurisdiction of Commissioner - Provisional release of goods order - The faulty premise is that the Commissioner of Customs cannot adjudicate a matter which involves duty of less than 50 lacs. The extract of the circular dated 31.05.2011 makes it clear that the Commissioner of Customs has authority to adjudicate all cases without limit. - HC
Jurisdiction of Commissioner - Provisional release of goods order - The faulty premise is that the Commissioner of Customs cannot adjudicate a matter which involves duty of less than 50 lacs. The extract of the circular dated 31.05.2011 makes it clear that the Commissioner of Customs has authority to adjudicate all cases without limit. - HC
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