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 upheld preventive detention order under COFEPOSA Act against petitioner involved in smuggling foreign gold through Gaya International Airport. Despite petitioner's custody in related criminal case, court found detention justified per established precedents. Court rejected argument that existing criminal proceedings precluded preventive detention, citing Haradhan Saha and Ameena Begum decisions. Procedural challenge regarding delay in order communication dismissed as records showed proper execution and compliance with statutory timelines. HC confirmed detaining authority followed constitutional, statutory, and procedural requirements, with valid subjective satisfaction based on relevant materials. Detention order maintained as necessary preventive measure distinct from punitive criminal proceedings. Writ petition dismissed.
HC upheld preventive detention order under COFEPOSA Act against petitioner involved in smuggling foreign gold through Gaya International Airport. Despite petitioner's custody in related criminal case, court found detention justified per established precedents. Court rejected argument that existing criminal proceedings precluded preventive detention, citing Haradhan Saha and Ameena Begum decisions. Procedural challenge regarding delay in order communication dismissed as records showed proper execution and compliance with statutory timelines. HC confirmed detaining authority followed constitutional, statutory, and procedural requirements, with valid subjective satisfaction based on relevant materials. Detention order maintained as necessary preventive measure distinct from punitive criminal proceedings. Writ petition dismissed.
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