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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Suspension of Customs Broker License - It is true that suspension is required only in cases where the Commissioner feels the need for immediate action. But this assessment of need for immediate action should be based on prima facie view about the role played by the Customs Broker. Had the Commissioner suspended the license of the Customs Broker as soon as the alleged illegal export was suspected, such an action would not have been sustainable because the appellant was not the exporter but had only facilitated filing of export documents. - this is merely an order of suspension of license and the appellant has full opportunity to explain his case and put forth his defence in the proceedings for action under Regulation 14 of CBLR, 2018 which are already in process - AT
Suspension of Customs Broker License - It is true that suspension is required only in cases where the Commissioner feels the need for immediate action. But this assessment of need for immediate action should be based on prima facie view about the role played by the Customs Broker. Had the Commissioner suspended the license of the Customs Broker as soon as the alleged illegal export was suspected, such an action would not have been sustainable because the appellant was not the exporter but had only facilitated filing of export documents. - this is merely an order of suspension of license and the appellant has full opportunity to explain his case and put forth his defence in the proceedings for action under Regulation 14 of CBLR, 2018 which are already in process - AT
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