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 a Russian tourist regarding customs detention of a gold chain. The court established three key principles: (1) bona fide personal jewelry falls under "personal effects" in Baggage Rules, requiring customs to distinguish between general jewelry and personal jewelry; (2) Baggage Rules have limited applicability to foreign tourists; and (3) the standard waiver form for show cause notice violates Section 124 of Customs Act and natural justice principles. The detention was deemed unlawful, and the court ordered release of the gold chain subject to applicable charges within four weeks. The ruling emphasizes that customs officials must evaluate tourist belongings case-by-case rather than applying mechanical detention procedures.
HC ruled in favor of a Russian tourist regarding customs detention of a gold chain. The court established three key principles: (1) bona fide personal jewelry falls under "personal effects" in Baggage Rules, requiring customs to distinguish between general jewelry and personal jewelry; (2) Baggage Rules have limited applicability to foreign tourists; and (3) the standard waiver form for show cause notice violates Section 124 of Customs Act and natural justice principles. The detention was deemed unlawful, and the court ordered release of the gold chain subject to applicable charges within four weeks. The ruling emphasizes that customs officials must evaluate tourist belongings case-by-case rather than applying mechanical detention procedures.
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