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 central issue was whether preventive seizure under Section 110(1) was jurisdictionally valid and supported by a "reason to believe." The court held that an officer's prima facie satisfaction based on contemporaneous material (interception near the Indo-Bangladesh border, route deviation and other circumstances) suffices; courts will not dissect the reasons so long as reasonable belief is shown, hence preventive powers under Section 110 extend to inland areas proximate to borders and do not amount to a roving enquiry - outcome: seizure and related orders upheld and appeal dismissed; domestic-trade claim held rebuttable under Section 124. - HC
The central issue was whether preventive seizure under Section 110(1) was jurisdictionally valid and supported by a "reason to believe." The court held that an officer's prima facie satisfaction based on contemporaneous material (interception near the Indo-Bangladesh border, route deviation and other circumstances) suffices; courts will not dissect the reasons so long as reasonable belief is shown, hence preventive powers under Section 110 extend to inland areas proximate to borders and do not amount to a roving enquiry - outcome: seizure and related orders upheld and appeal dismissed; domestic-trade claim held rebuttable under Section 124. - HC
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