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 held that respondents must release seized jewellery immediately, as retention lacks legal authority. The seizure was deemed unauthorized since no outstanding tax liability existed for the relevant assessment year. The court found respondents' contention to retain jewellery for recovering tax dues from subsequent years untenable, particularly given statutory amendments to Section 132B effective 01.04.2022. Consequently, the HC directed unconditional release of the jewellery to the petitioner, emphasizing the respondents acted without jurisdiction in prolonged retention beyond the specified assessment period.
HC held that respondents must release seized jewellery immediately, as retention lacks legal authority. The seizure was deemed unauthorized since no outstanding tax liability existed for the relevant assessment year. The court found respondents' contention to retain jewellery for recovering tax dues from subsequent years untenable, particularly given statutory amendments to Section 132B effective 01.04.2022. Consequently, the HC directed unconditional release of the jewellery to the petitioner, emphasizing the respondents acted without jurisdiction in prolonged retention beyond the specified assessment period.
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