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 dismissed the petition challenging revocation of petitioner's courier license and forfeiture of security deposit for violating Regulations 13(a), 13(c), 13(g), 13(i) and 13(j) of the Courier Imports And Exports (Clearance) Regulations, 1998. The court found serious violations of Regulations 13(a), 13(i), and 13(g), including false declarations regarding consignee authorization, failure to verify client antecedents despite clearing 250 consignments in six months, and inadequate record maintenance. While the court found no violation of Regulation 13(j), the remaining violations justified the penalty. The court rejected the disproportionality argument, noting that two consignments contained smuggled gold totaling 4879.9 grams, creating vicarious liability. Citing precedent from Delhi HC in Bombino Express case, the court upheld the authorities' discretion in license revocation absent perversity or conscience-shocking circumstances.
The HC dismissed the petition challenging revocation of petitioner's courier license and forfeiture of security deposit for violating Regulations 13(a), 13(c), 13(g), 13(i) and 13(j) of the Courier Imports And Exports (Clearance) Regulations, 1998. The court found serious violations of Regulations 13(a), 13(i), and 13(g), including false declarations regarding consignee authorization, failure to verify client antecedents despite clearing 250 consignments in six months, and inadequate record maintenance. While the court found no violation of Regulation 13(j), the remaining violations justified the penalty. The court rejected the disproportionality argument, noting that two consignments contained smuggled gold totaling 4879.9 grams, creating vicarious liability. Citing precedent from Delhi HC in Bombino Express case, the court upheld the authorities' discretion in license revocation absent perversity or conscience-shocking circumstances.
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