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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The HC upheld the rejection of petitioner's application for compounding an offense under Section 137 of the Customs Act, 1962. The court determined that compounding applications require scrutiny and the compounding officer's subjective satisfaction that the disclosure was full and true. In this case, substantial variance existed between petitioner's statements under Section 108 and in the Panchnama compared to the compounding application, without any retraction of earlier statements. The court emphasized that compounding is not a routine entitlement and dismissed the petition, finding the rejection justified due to petitioner's failure to make full and true disclosure of facts as required by applicable circulars.
The HC upheld the rejection of petitioner's application for compounding an offense under Section 137 of the Customs Act, 1962. The court determined that compounding applications require scrutiny and the compounding officer's subjective satisfaction that the disclosure was full and true. In this case, substantial variance existed between petitioner's statements under Section 108 and in the Panchnama compared to the compounding application, without any retraction of earlier statements. The court emphasized that compounding is not a routine entitlement and dismissed the petition, finding the rejection justified due to petitioner's failure to make full and true disclosure of facts as required by applicable circulars.
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