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 ruled in favor of petitioner seeking release of detained wristwatch, holding that failure to issue show cause notice violated principles of natural justice. While petitioner's delayed submission of documents in response to February email was noted, the court emphasized that procedural requirement of show cause notice cannot be bypassed. Following precedent, absence of show cause notice rendered the detention invalid. Court directed unconditional release of goods within two weeks. Though petitioner's delayed disclosure was problematic, the fundamental procedural defect in detention process necessitated release. Petition succeeded on grounds of violation of natural justice principles.
HC ruled in favor of petitioner seeking release of detained wristwatch, holding that failure to issue show cause notice violated principles of natural justice. While petitioner's delayed submission of documents in response to February email was noted, the court emphasized that procedural requirement of show cause notice cannot be bypassed. Following precedent, absence of show cause notice rendered the detention invalid. Court directed unconditional release of goods within two weeks. Though petitioner's delayed disclosure was problematic, the fundamental procedural defect in detention process necessitated release. Petition succeeded on grounds of violation of natural justice principles.
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