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 determined that while the show cause notice (SCN) dated 02.12.2014 issued by Additional Director General, DRI Chennai Zonal Unit qualified as an offense report, there was insufficient evidence to establish the respondent's knowledge or receipt of this notice. Unlike precedent in A.M.Ahamed case where SCN copies were explicitly marked to relevant authorities, no documentation proved the 02.12.2014 SCN was communicated to Commissioner of Customs, Tuticorin. The court found that mere existence of an offense report is inadequate; actual knowledge or receipt must be demonstrated to satisfy jurisdictional requirements. The limitation period of 90 days cannot be considered breached without establishing proper service or awareness of the initial SCN. Appeal allowed.
HC determined that while the show cause notice (SCN) dated 02.12.2014 issued by Additional Director General, DRI Chennai Zonal Unit qualified as an offense report, there was insufficient evidence to establish the respondent's knowledge or receipt of this notice. Unlike precedent in A.M.Ahamed case where SCN copies were explicitly marked to relevant authorities, no documentation proved the 02.12.2014 SCN was communicated to Commissioner of Customs, Tuticorin. The court found that mere existence of an offense report is inadequate; actual knowledge or receipt must be demonstrated to satisfy jurisdictional requirements. The limitation period of 90 days cannot be considered breached without establishing proper service or awareness of the initial SCN. Appeal allowed.
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