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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Cancellation of the IEC - EPCG Scheme - levy of penalty - the learned Judge while disposing the writ petition filed by the appellant, challenging the order of cancellation of IEC passed by the third respondent, has correctly directed the jurisdictional officer under the Act, to issue appropriate show cause notice to the appellant, within a period of 30 days from the date of receipt of a copy of the order; further directed the appellant to file a reply within a period of 30 days; and thereafter, directed the jurisdictional officer to pass appropriate order, in accordance with law, within a period of 90 days, after giving adequate opportunity of hearing to the appellant. Further, the interest of the appellant was rightly protected by extending the status quo order for a period of 90 days. - HC
Cancellation of the IEC - EPCG Scheme - levy of penalty - the learned Judge while disposing the writ petition filed by the appellant, challenging the order of cancellation of IEC passed by the third respondent, has correctly directed the jurisdictional officer under the Act, to issue appropriate show cause notice to the appellant, within a period of 30 days from the date of receipt of a copy of the order; further directed the appellant to file a reply within a period of 30 days; and thereafter, directed the jurisdictional officer to pass appropriate order, in accordance with law, within a period of 90 days, after giving adequate opportunity of hearing to the appellant. Further, the interest of the appellant was rightly protected by extending the status quo order for a period of 90 days. - HC
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