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 declined to adjudicate the substantive merits and limited its review to the provisional release order, finding some conditions unduly onerous. The court modified the provisional release terms: the Petitioner must remit the full duty declared by it and pay 50% of the differential duty assessed by the Department on re-determination of value. The HC set aside the requirement to furnish a Bank Guarantee of Rs.11,00,000 and held the remaining conditions adequate to protect the Department's interest while permitting release. Consequential direction follows for release of the goods on compliance with the altered financial conditions. Writ petition disposed.
HC declined to adjudicate the substantive merits and limited its review to the provisional release order, finding some conditions unduly onerous. The court modified the provisional release terms: the Petitioner must remit the full duty declared by it and pay 50% of the differential duty assessed by the Department on re-determination of value. The HC set aside the requirement to furnish a Bank Guarantee of Rs.11,00,000 and held the remaining conditions adequate to protect the Department's interest while permitting release. Consequential direction follows for release of the goods on compliance with the altered financial conditions. Writ petition disposed.
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