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 directed provisional release of seized wheat flour sheet dough imports covered under six Bills of Entry. Absent a Show Cause Notice, requiring bank guarantee for anticipated redemption fine and penalties was deemed excessive. Court ordered release conditional upon petitioner furnishing Provisional Duty Bond for full assessable value and bank guarantee of Rs.85 Lakhs (approximately 50% of differential duty) within one week. Customs Department instructed to release goods within one week of receiving documentation. This balanced approach protects revenue interests while avoiding undue financial burden on importer pending final classification determination. Petition disposed of with structured release mechanism.
HC directed provisional release of seized wheat flour sheet dough imports covered under six Bills of Entry. Absent a Show Cause Notice, requiring bank guarantee for anticipated redemption fine and penalties was deemed excessive. Court ordered release conditional upon petitioner furnishing Provisional Duty Bond for full assessable value and bank guarantee of Rs.85 Lakhs (approximately 50% of differential duty) within one week. Customs Department instructed to release goods within one week of receiving documentation. This balanced approach protects revenue interests while avoiding undue financial burden on importer pending final classification determination. Petition disposed of with structured release mechanism.
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