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, while noting that the imported goods (viscose knitted fabric) are subject to pending adjudication for alleged misclassification and undervaluation, modified the impugned provisional release order. The court refused to endorse onerous prerequisites such as unconditional release without fiscal safeguards, but directed that the petitioner must remit the full duty as declared in the import documents and additionally pay 50% of the differential duty computed by the Department on its reassessed value; the balance differential duty remains subject to outcome of the adjudication. All other conditions of provisional release were accordingly read down and the writ petition was disposed of.
The HC, while noting that the imported goods (viscose knitted fabric) are subject to pending adjudication for alleged misclassification and undervaluation, modified the impugned provisional release order. The court refused to endorse onerous prerequisites such as unconditional release without fiscal safeguards, but directed that the petitioner must remit the full duty as declared in the import documents and additionally pay 50% of the differential duty computed by the Department on its reassessed value; the balance differential duty remains subject to outcome of the adjudication. All other conditions of provisional release were accordingly read down and the writ petition was disposed of.
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