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 disposed the petition, directing release of all consignments except two, subject to conditions and pending adjudication. The court accepted the CRCL/FSSAI reports showing moisture content below 10% for most consignments, thereby classifying them as roasted areca nut rather than raw, and noted ten consignments had already been released. Because the Notification purporting to render roasted areca nut prohibited below a specified CIF value is stayed, the goods cannot presently be treated as prohibited; accordingly, further detention would be inappropriate given perishability. The respondents are restricted to initiating adjudication proceedings and proceeding in accordance with law; no prejudice will result from ordered releases.
The HC disposed the petition, directing release of all consignments except two, subject to conditions and pending adjudication. The court accepted the CRCL/FSSAI reports showing moisture content below 10% for most consignments, thereby classifying them as roasted areca nut rather than raw, and noted ten consignments had already been released. Because the Notification purporting to render roasted areca nut prohibited below a specified CIF value is stayed, the goods cannot presently be treated as prohibited; accordingly, further detention would be inappropriate given perishability. The respondents are restricted to initiating adjudication proceedings and proceeding in accordance with law; no prejudice will result from ordered releases.
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