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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Provisional release of seized goods - The differential duty already paid is with respect to the recovered parallel invoices and the demand now raised in Exhibit P8 is based on the computation of probable undervaluation with respect to the other bills of entry, which also disclosed only lesser invoice value as admitted by the Managing Partner of the appellant. - On the apprehension raised by the appellant that release would be only on deposit of cash, we make it clear that the order itself provides for execution of bond or Bank Guarantee to the satisfaction of the Commissioner. - HC
Provisional release of seized goods - The differential duty already paid is with respect to the recovered parallel invoices and the demand now raised in Exhibit P8 is based on the computation of probable undervaluation with respect to the other bills of entry, which also disclosed only lesser invoice value as admitted by the Managing Partner of the appellant. - On the apprehension raised by the appellant that release would be only on deposit of cash, we make it clear that the order itself provides for execution of bond or Bank Guarantee to the satisfaction of the Commissioner. - HC
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