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 directed the return of electronic devices seized from Petitioners in a gold smuggling case, after the Respondent copies all data. If any downloaded documents are used in show cause proceedings or prosecution complaints, these Relied Upon Documents must be listed and provided to Petitioners. In exchange, Petitioners agreed not to raise objections regarding non-fulfillment of requirements under Section 63 of the Bharatiya Sakshya Adhiniyam, 2023 and Section 138C of the Customs Act, 1962. The Court recommended this approach be adopted by all Customs Commissionerates to avoid prolonged retention of devices which may become outdated, while ensuring data remains accessible to investigation officers through proper copying and server storage.
The HC directed the return of electronic devices seized from Petitioners in a gold smuggling case, after the Respondent copies all data. If any downloaded documents are used in show cause proceedings or prosecution complaints, these Relied Upon Documents must be listed and provided to Petitioners. In exchange, Petitioners agreed not to raise objections regarding non-fulfillment of requirements under Section 63 of the Bharatiya Sakshya Adhiniyam, 2023 and Section 138C of the Customs Act, 1962. The Court recommended this approach be adopted by all Customs Commissionerates to avoid prolonged retention of devices which may become outdated, while ensuring data remains accessible to investigation officers through proper copying and server storage.
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