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 broker's license revocation order set aside due to lack of evidence for alleged violations. Key findings: no proof of misdeclaration or undervaluation to establish violation of due diligence under Regulation 10(e); KYC norms followed as per instructions, no violation of 10(n); inadvertent error in referring to 10(q) instead of 10(n) in order; authorized signatories approved by Customs authorities, no unauthorized handling under Regulations 13(3), 13(4), 13(7), 13(12). Procedural lapses: undue delay in inquiry completion beyond stipulated timeline; improper deemed suspension despite ongoing suspension; no legal provision for future deemed suspension. Order unsustainable due to lack of evidence for violations and procedural irregularities.
Customs broker's license revocation order set aside due to lack of evidence for alleged violations. Key findings: no proof of misdeclaration or undervaluation to establish violation of due diligence under Regulation 10(e); KYC norms followed as per instructions, no violation of 10(n); inadvertent error in referring to 10(q) instead of 10(n) in order; authorized signatories approved by Customs authorities, no unauthorized handling under Regulations 13(3), 13(4), 13(7), 13(12). Procedural lapses: undue delay in inquiry completion beyond stipulated timeline; improper deemed suspension despite ongoing suspension; no legal provision for future deemed suspension. Order unsustainable due to lack of evidence for violations and procedural irregularities.
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