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 dismissed the petition challenging Show Cause Notice (SCN) related to duty drawback scheme. The Court found no limitation bar for issuing SCNs due to fraudulent export documentation, where significant invoice value discrepancies were discovered (inflated from 2,176 USD to 56,032 USD). While declining direct writ intervention, the Court permitted the petitioner to pursue statutory appellate remedy under Section 128 of Customs Act, 1962, emphasizing that alternative legal recourse exists to contest the SCN's substantive allegations. The petition was disposed of, directing the petitioner to follow prescribed statutory appellate mechanism.
HC dismissed the petition challenging Show Cause Notice (SCN) related to duty drawback scheme. The Court found no limitation bar for issuing SCNs due to fraudulent export documentation, where significant invoice value discrepancies were discovered (inflated from 2,176 USD to 56,032 USD). While declining direct writ intervention, the Court permitted the petitioner to pursue statutory appellate remedy under Section 128 of Customs Act, 1962, emphasizing that alternative legal recourse exists to contest the SCN's substantive allegations. The petition was disposed of, directing the petitioner to follow prescribed statutory appellate mechanism.
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