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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Misue of high positions of “Commissioner” - Provisional release of seized goods - It seems that the Additional Commissioner, while passing this order has not acted as quasi judicial authority but an agent of investigating team of DRI officers and have instead of implementing the rule of law has decided to implement the will of the investigating authorities. Such an approach or interference in quasi judicial functioning by the investigating authorities is totally uncalled for and is condemned. - AT
Misue of high positions of “Commissioner” - Provisional release of seized goods - It seems that the Additional Commissioner, while passing this order has not acted as quasi judicial authority but an agent of investigating team of DRI officers and have instead of implementing the rule of law has decided to implement the will of the investigating authorities. Such an approach or interference in quasi judicial functioning by the investigating authorities is totally uncalled for and is condemned. - AT
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