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 allowed the writ petitions and set aside the impugned suspension orders as bereft of jurisdiction, holding that only the Parent Commissionerate (the license-granting authority) may suspend a Customs Broker licence under the Regulations and s.146 framework; a Non-Parent Commissioner may issue only a time-limited prohibition within its Customs Station under Regulation 15, not a suspension under Regulation 16. The Board's earlier circular made under prior Regulations remains operative to the extent consistent with the 2018 Regulations. Consequentially, suspension orders issued by a Commissioner who is not the licence-granting authority are quashed and the petitions granted.
The HC allowed the writ petitions and set aside the impugned suspension orders as bereft of jurisdiction, holding that only the Parent Commissionerate (the license-granting authority) may suspend a Customs Broker licence under the Regulations and s.146 framework; a Non-Parent Commissioner may issue only a time-limited prohibition within its Customs Station under Regulation 15, not a suspension under Regulation 16. The Board's earlier circular made under prior Regulations remains operative to the extent consistent with the 2018 Regulations. Consequentially, suspension orders issued by a Commissioner who is not the licence-granting authority are quashed and the petitions granted.
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