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 dismissed the petition and upheld the detention and seizure of goods, holding that the impounding was founded on a contemporaneous, categorical statement by the vehicle driver that contradicted the documentary route claim. The Court found the driver's first-instance statement unrebutted, not procured under duress, and more probative than subsequent explanations; absence of any challenge to the statement's voluntariness or authenticity precluded its discredit. Consequently, the impugned orders were not arbitrary and the documentary evidence purporting a different origin was deemed unhelpful to the petitioner. Relief was refused and the administrative seizure and related orders affirmed.
HC dismissed the petition and upheld the detention and seizure of goods, holding that the impounding was founded on a contemporaneous, categorical statement by the vehicle driver that contradicted the documentary route claim. The Court found the driver's first-instance statement unrebutted, not procured under duress, and more probative than subsequent explanations; absence of any challenge to the statement's voluntariness or authenticity precluded its discredit. Consequently, the impugned orders were not arbitrary and the documentary evidence purporting a different origin was deemed unhelpful to the petitioner. Relief was refused and the administrative seizure and related orders affirmed.
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