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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Customs department's conduct was wrongful, vindictive, and gross abuse of power in restricting petitioner's exit without justification, despite acquittal on merit in smuggling case. Court invoked Section 482 CrPC for complete justice, as respondent's conduct was reprehensible and unbecoming. Articles 20, 21, and 22 rights extend to non-citizens. Petitioner granted exit permit within two weeks and Rs. 10,00,000 compensation for mental agony, trauma, and sufferings due to respondent's conduct. Petition allowed.
Customs department's conduct was wrongful, vindictive, and gross abuse of power in restricting petitioner's exit without justification, despite acquittal on merit in smuggling case. Court invoked Section 482 CrPC for complete justice, as respondent's conduct was reprehensible and unbecoming. Articles 20, 21, and 22 rights extend to non-citizens. Petitioner granted exit permit within two weeks and Rs. 10,00,000 compensation for mental agony, trauma, and sufferings due to respondent's conduct. Petition allowed.
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