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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Confiscation of the currency seized - validity of order for release on payment of redemption fine - The High court found that the seizure and confiscation of foreign currency were justified under Sections 113(d), 113(e), and 113(h) of the Customs Act, 1962, read with the Foreign Exchange Management (Export and Import of Currency) Regulations, 2015. - The Court found that, there are no notifications issued u/s 11-I of the Customs Act, 1962. - The court observed that the appellate authority properly exercised discretion u/s 125 by allowing the redemption of the seized currency upon payment of a fine, modifying the Order-in-Original to reduce the penalty and allow for the currency's redemption.
Confiscation of the currency seized - validity of order for release on payment of redemption fine - The High court found that the seizure and confiscation of foreign currency were justified under Sections 113(d), 113(e), and 113(h) of the Customs Act, 1962, read with the Foreign Exchange Management (Export and Import of Currency) Regulations, 2015. - The Court found that, there are no notifications issued u/s 11-I of the Customs Act, 1962. - The court observed that the appellate authority properly exercised discretion u/s 125 by allowing the redemption of the seized currency upon payment of a fine, modifying the Order-in-Original to reduce the penalty and allow for the currency's redemption.
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