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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HC overturned absolute confiscation of undeclared gold jewelry seized at airport from Dubai returnee. Following precedent in N. Kaliyamoorthy case, court held that absolute confiscation under Section 125 of Customs Act 1962 was inappropriate. While undeclared goods violating import conditions qualify as "prohibited" and are subject to confiscation, complete forfeiture was deemed excessive. Court remanded case to customs authority with directions to permit redemption upon payment of appropriate fine. Jurisdictional challenge by respondents was dismissed as cause of action arose within court's jurisdiction. Original confiscation order and subsequent appellate confirmation were set aside. Petition succeeded with modified penalty approach allowing for possible recovery of goods.
HC overturned absolute confiscation of undeclared gold jewelry seized at airport from Dubai returnee. Following precedent in N. Kaliyamoorthy case, court held that absolute confiscation under Section 125 of Customs Act 1962 was inappropriate. While undeclared goods violating import conditions qualify as "prohibited" and are subject to confiscation, complete forfeiture was deemed excessive. Court remanded case to customs authority with directions to permit redemption upon payment of appropriate fine. Jurisdictional challenge by respondents was dismissed as cause of action arose within court's jurisdiction. Original confiscation order and subsequent appellate confirmation were set aside. Petition succeeded with modified penalty approach allowing for possible recovery of goods.
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