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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Continuation of suspension of ‘customs broker’ licence - such instances of suspension should be followed by proceedings, including issue of chargesheet within the prescribed timeframe, for it to be bona fide exercise of authority. The time limit for initiating such action in all, and any, circumstances has also lapsed. The pre-condition for invoking the power of suspension, viz., that of temporary detriment pending initiation and conclusion of proceedings for revocation, did not appear to have been intended to be complied with at all. - The suspension is set aside and the licence restored for operation - AT
Continuation of suspension of ‘customs broker’ licence - such instances of suspension should be followed by proceedings, including issue of chargesheet within the prescribed timeframe, for it to be bona fide exercise of authority. The time limit for initiating such action in all, and any, circumstances has also lapsed. The pre-condition for invoking the power of suspension, viz., that of temporary detriment pending initiation and conclusion of proceedings for revocation, did not appear to have been intended to be complied with at all. - The suspension is set aside and the licence restored for operation - AT
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