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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Seeking to release the raw materials, goods, stock and finished goods seized and detained by the official respondents - A mere lock and seal of the premises is not sufficient to conclude a valid seizure if there is no Seizure Mahazar. The officer themselves can allow the release of the goods lying in the distillery of the fourth respondent. Either way, raw materials of the petitioner cannot be retained - the petitioner has made out a case for release of the raw materials - HC
Seeking to release the raw materials, goods, stock and finished goods seized and detained by the official respondents - A mere lock and seal of the premises is not sufficient to conclude a valid seizure if there is no Seizure Mahazar. The officer themselves can allow the release of the goods lying in the distillery of the fourth respondent. Either way, raw materials of the petitioner cannot be retained - the petitioner has made out a case for release of the raw materials - HC
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