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 HC quashed the show cause notice (SCN) issued u/s 28(9) of the Customs Act, 1962 due to an inordinate delay of almost eight years in adjudication. Despite the petitioner's reply to the SCN dated 17.04.2015, no adjudication was conducted. The HC held that there was no justifiable reason for the non-adjudication, and the facts did not reveal any impossibility for the Customs Department to deal with the SCN. Consequently, the impugned SCN deserved to be quashed, and the petition was allowed.
The HC quashed the show cause notice (SCN) issued u/s 28(9) of the Customs Act, 1962 due to an inordinate delay of almost eight years in adjudication. Despite the petitioner's reply to the SCN dated 17.04.2015, no adjudication was conducted. The HC held that there was no justifiable reason for the non-adjudication, and the facts did not reveal any impossibility for the Customs Department to deal with the SCN. Consequently, the impugned SCN deserved to be quashed, and the petition was allowed.
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