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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Extension of period of seizure beyond 6 months - Principles of Natural Justice - Jurisdiction - whether power under the first proviso under Section 110(2) of the Act of 1962 is quasi-judicial in nature and requires a judicial approach? - The authorities were required to give an opportunity of hearing to the person from whom the goods were seized before exercising power under Section 110(2) of the Act of 1962 which they did not do while issuing the impugned order - Simply on the ground of breach of principles of natural justice, the impugned order is set aside. - The authorities are at liberty to take steps in accordance with law. - HC
Extension of period of seizure beyond 6 months - Principles of Natural Justice - Jurisdiction - whether power under the first proviso under Section 110(2) of the Act of 1962 is quasi-judicial in nature and requires a judicial approach? - The authorities were required to give an opportunity of hearing to the person from whom the goods were seized before exercising power under Section 110(2) of the Act of 1962 which they did not do while issuing the impugned order - Simply on the ground of breach of principles of natural justice, the impugned order is set aside. - The authorities are at liberty to take steps in accordance with law. - HC
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