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 directed that the seized gold chain be released to the Petitioner due to non-compliance with statutory timelines and breach of natural justice by the Customs respondent. Because no show-cause notice was issued within the six-month period (extendable by six months) prescribed under Section 110 and no provisional release occurred, the Court held the statutory consequence requires release. The Petitioner, a resident of Iran, may re-export the gold; release is ordered subject to payment of applicable warehousing charges as of the date of detention. The petition is disposed of accordingly, with the Customs respondent to effect release within one month.
The HC directed that the seized gold chain be released to the Petitioner due to non-compliance with statutory timelines and breach of natural justice by the Customs respondent. Because no show-cause notice was issued within the six-month period (extendable by six months) prescribed under Section 110 and no provisional release occurred, the Court held the statutory consequence requires release. The Petitioner, a resident of Iran, may re-export the gold; release is ordered subject to payment of applicable warehousing charges as of the date of detention. The petition is disposed of accordingly, with the Customs respondent to effect release within one month.
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