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 quashed confiscation order under section 112(a)(i) of Customs Act, 1962 for concealing foreign currency seized from petitioner arriving from USA. The ex-parte order violated principles of natural justice as customs authorities failed to serve show-cause notice at petitioner's USA address disclosed in statement and passport, instead relying on insufficient local address at Anand. Court rejected respondent's excuse regarding returned notice marked "insufficient address" and reliance on section 153(e) for substituted service through notice board affixation. Matter remanded to customs authorities for fresh de novo proceedings after providing proper opportunity of hearing to petitioner in accordance with law.
HC quashed confiscation order under section 112(a)(i) of Customs Act, 1962 for concealing foreign currency seized from petitioner arriving from USA. The ex-parte order violated principles of natural justice as customs authorities failed to serve show-cause notice at petitioner's USA address disclosed in statement and passport, instead relying on insufficient local address at Anand. Court rejected respondent's excuse regarding returned notice marked "insufficient address" and reliance on section 153(e) for substituted service through notice board affixation. Matter remanded to customs authorities for fresh de novo proceedings after providing proper opportunity of hearing to petitioner in accordance with law.
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