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 declined to adjudicate the merits and confined review to the provisional release order, finding certain onerous conditions susceptible to modification; accordingly the HC modified those conditions and directed the respondents to release the seized goods upon compliance with the revised conditions, including execution of bonds for differential duty and adjudication levies as appropriate, while permitting the Department to continue adjudication proceedings. The petitioner was ordered to cooperate to enable expeditious completion of adjudication. The writ petition challenging the provisional release conditions was disposed of consistent with these directions.
The HC declined to adjudicate the merits and confined review to the provisional release order, finding certain onerous conditions susceptible to modification; accordingly the HC modified those conditions and directed the respondents to release the seized goods upon compliance with the revised conditions, including execution of bonds for differential duty and adjudication levies as appropriate, while permitting the Department to continue adjudication proceedings. The petitioner was ordered to cooperate to enable expeditious completion of adjudication. The writ petition challenging the provisional release conditions was disposed of consistent with these directions.
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