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 declined to exercise discretionary jurisdiction to stay or quash the show-cause notice issued against the Petitioner in relation to the alleged smuggling of gold. The Court found no basis to prima facie conclude the Petitioner intended to smuggle gold into India but upheld that the customs authorities had sufficient grounds to raise suspicion, given the Petitioner's repeated carriage of commercial quantities of gold and reliance on the Customs Notification dated 30 June 2017. The gold was lawfully seized pending investigation. The Court emphasized that the show-cause notice must be adjudicated on its merits without influence from this order, which addressed only the question of interim relief. The petition was accordingly dismissed, leaving the substantive adjudication to the customs authorities.
The HC declined to exercise discretionary jurisdiction to stay or quash the show-cause notice issued against the Petitioner in relation to the alleged smuggling of gold. The Court found no basis to prima facie conclude the Petitioner intended to smuggle gold into India but upheld that the customs authorities had sufficient grounds to raise suspicion, given the Petitioner's repeated carriage of commercial quantities of gold and reliance on the Customs Notification dated 30 June 2017. The gold was lawfully seized pending investigation. The Court emphasized that the show-cause notice must be adjudicated on its merits without influence from this order, which addressed only the question of interim relief. The petition was accordingly dismissed, leaving the substantive adjudication to the customs authorities.
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