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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The High Court considered jurisdiction for Anticipatory Bail Applications, extension of export obligation period, duty evasion, and confiscation of gold worth over Rs. 50 Lakhs. The importer failed to export processed articles within the specified period. Statements revealed discrepancies in gold processing and export. 37 kgs of imported gold went missing, indicating possible misappropriation. Duty payment and confiscation under u/s 111 (o) of Customs Act were warranted. Custodial interrogation of Applicants was deemed necessary due to seriousness of offense. Protection u/s 438 of Cr.P.C. was denied, and the Application was dismissed.
The High Court considered jurisdiction for Anticipatory Bail Applications, extension of export obligation period, duty evasion, and confiscation of gold worth over Rs. 50 Lakhs. The importer failed to export processed articles within the specified period. Statements revealed discrepancies in gold processing and export. 37 kgs of imported gold went missing, indicating possible misappropriation. Duty payment and confiscation under u/s 111 (o) of Customs Act were warranted. Custodial interrogation of Applicants was deemed necessary due to seriousness of offense. Protection u/s 438 of Cr.P.C. was denied, and the Application was dismissed.
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