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 provisional release of goods - Revenue found it necessary to insist upon additional security deposit - Section 110 of Customs Act, 1962 mandates release of goods within six month from the date of seizure unless show-cause notice proposing confiscation has been issued or, on compliance with prescribed procedure, within further six months. The pendency of appeal against the terms of release does not alter the prescription therein. - The retention of goods, not validated by issue of notice, is not tenable in law and must, in accordance with the law, be released unconditionally to the appellant. - AT
Seeking provisional release of goods - Revenue found it necessary to insist upon additional security deposit - Section 110 of Customs Act, 1962 mandates release of goods within six month from the date of seizure unless show-cause notice proposing confiscation has been issued or, on compliance with prescribed procedure, within further six months. The pendency of appeal against the terms of release does not alter the prescription therein. - The retention of goods, not validated by issue of notice, is not tenable in law and must, in accordance with the law, be released unconditionally to the appellant. - AT
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