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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Reclaim of goods after surrender of rights in warehoused Goods (after import) u/s 23(3) - Due to increased customs duty, the plaintiffs could not take the delivery of the goods - Since the plaintiffs have initially surrendered their right and claim over the goods, now they cannot reverse their stand and re-claim the same after inordinate delay without assigning any sufficient condonable reasons for the same. Rather what appears is that the suit filed by the plaintiffs is an afterthought belated machination by misuse of the process of the Court - HC
Reclaim of goods after surrender of rights in warehoused Goods (after import) u/s 23(3) - Due to increased customs duty, the plaintiffs could not take the delivery of the goods - Since the plaintiffs have initially surrendered their right and claim over the goods, now they cannot reverse their stand and re-claim the same after inordinate delay without assigning any sufficient condonable reasons for the same. Rather what appears is that the suit filed by the plaintiffs is an afterthought belated machination by misuse of the process of the Court - HC
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