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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Disposal of seized gold jewellery without intimation to the affected person and adjudicatory authorities is condemned as breach of natural justice, and administrative disposal without notice is unlawful; consequence: entitlement to compensation at prevailing market value for the seized 1110 grams. Unlawful reduction of refund by deducting customs duty or using a lower recovered amount is impermissible where re-export has been ordered; consequence: refund must reflect full market rate. Supervisory review of administrative disposal and refund orders is affirmed as a remedy to direct payment and further costs for non-compliance.
Disposal of seized gold jewellery without intimation to the affected person and adjudicatory authorities is condemned as breach of natural justice, and administrative disposal without notice is unlawful; consequence: entitlement to compensation at prevailing market value for the seized 1110 grams. Unlawful reduction of refund by deducting customs duty or using a lower recovered amount is impermissible where re-export has been ordered; consequence: refund must reflect full market rate. Supervisory review of administrative disposal and refund orders is affirmed as a remedy to direct payment and further costs for non-compliance.
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