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 directed provisional release of seized cashew kernels upon petitioner furnishing bank guarantee of Rs. 2.5 crores and bond of Rs. 3.25 crores within seven days. Court rejected petitioner's initial offer of Rs. 1 crore guarantee as insufficient. Seizure involved classification dispute regarding plain versus roasted cashew kernels under bills of entry and whether goods constituted prohibited items. Court noted petitioner possessed Advance Ruling Authority decision and Mumbai Lab report supporting their position, while acknowledging respondents' contrary material required examination during show cause notice proceedings. Regarding detention demurrage charges, court permitted petitioner to seek waiver from respondents, directing disposal according to law. All contentions remain open for final adjudication. Petition disposed of with conditional release order to prevent goods deterioration.
HC directed provisional release of seized cashew kernels upon petitioner furnishing bank guarantee of Rs. 2.5 crores and bond of Rs. 3.25 crores within seven days. Court rejected petitioner's initial offer of Rs. 1 crore guarantee as insufficient. Seizure involved classification dispute regarding plain versus roasted cashew kernels under bills of entry and whether goods constituted prohibited items. Court noted petitioner possessed Advance Ruling Authority decision and Mumbai Lab report supporting their position, while acknowledging respondents' contrary material required examination during show cause notice proceedings. Regarding detention demurrage charges, court permitted petitioner to seek waiver from respondents, directing disposal according to law. All contentions remain open for final adjudication. Petition disposed of with conditional release order to prevent goods deterioration.
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